Book Review: “Easy Money”

I recently finished reading the Kindle version of Easy Money by Ben McKenzie and Jacob Silverman. Simultaneously, I also read Number Go Up from Zeke Faux, another blockchain-focused book that came out about two months after the publication of Easy Money. These would make the 10th and 11th blockchain-specific books I have reviewed. See the full list here.

Easy Money was not the worst blockchain-related book I have read, that award would go to Popping the Crypto Bubble. Easy Money had a lot of potential, in fact, several chapters had some pretty good prose and first-hand reporting.

But for some inexplicable reason – unlike most of the other blockchain books I have reviewed – the authors insert Ben McKenzie into the story for no apparent reason.

Previous books written by reporters might explain in first person how difficult it was to use a wallet or how difficult it was to explain mining to someone – but McKenzie finds a way to insert himself into every chapter even if he is irrelevant.1 And that takes a lot away from what could have been a powerful book.

For instance, Chapter 7 was probably the best written and interesting chapter of the book. The two authors flew down to El Salvador to investigate what kind of traction Bitcoin-based payments was having in the small Central American country. And as the authors describe the plight of one of the residents who is unlucky to live on land that was to be turned into an airport, they write:

Here was a famous Hollywood actor who wanted to film and interview him, to tell his story, yet no one in his own country could tell him when he would be kicked off his land or where he might go.

The reader is constantly reminded of how McKenzie was in several popular TV shows. In all but one other blockchain book I have reviewed few authors attempt to regularly remind people of who they are. The main exception is Fais Khan who wrote The Billionaire’s Folly, which was an insiders account of working at ConsenSys.

McKensie was not an insider. In his own words, he was stoned and out of work in late 2020, and came to the conclusion that he should pivot careers and write a book about crypto. Yet because he did not get really started until late 2021 – near the height of the recent bubble – it all comes across as Johnny-come-lately ambulance chasing self-serving plot filler to boost his PR so he can appear in the Netflix adaptation.2 It is both poor form and cringey.

Furthermore, the dual authors make a number of elementary mistakes. For instance on p. 36 they write: “In 2016, Tether was hacked. More than 100,000 Bitcoin (worth $71 million at the time) was stolen, and the company was in desperate straits.”

What they meant to write was that Bitfinex, the centralized exchange, was hacked. It was actually hacked twice in 2016, the second time 119,756 bitcoins were stolen.

Later, on p. 264 they write: “The other major player left standing was Tether. The stablecoin company, valued at $71 billion as of March 1, 2023, had miraculously survived while the industry around it bit the dust.”

This is not an accurate way of describing the company. The valuation of a bank – or in this case, a shadow bank – is usually determined by its book value of equity (BVE), not by how large its deposit base is. If we took its self-disclosed quarterly reports at face value, Tether LTD itself is worth several billion dollars. In contrast, the aggregate value of USDT spread across all chains, as of this writing, is around $86 billion. Academics such as Stephen Kelly, have publicly analyzed these claims, a future edition should include such remediations.

It is also worth pointing out that the book quickly glosses over any deep or detailed technical discussion and that is likely to help the reader move through the pages. Yet there is no glossary for further explanations and the Appendix consists of a single page copied from the SEC website regarding Ponzi schemes.

This is kind of strange considering even Diehl’s book at least paid some lip service towards the technical bits. To be fair though, unlike Diehl’s book, McKenzie and Silverman do not repeat the same refrain over and over again. But that should not be the bar. With the resources of a real publisher (Abrams), this should have been a top shelf book. But instead it is 1-star quality book and a hard pass.

As usual, all transcription errors are my own.

Chapter 1: Money and Lying

On page 1 the authors write:

These get-rich-quick speculative schemes were merely the latest iteration of casino capitalism. Political economist Susan Strange populated the term in the 1980s, but its roots stretch at least as far back as the 1930s.

This may seem pedantic but I am pretty certain the authors meant to write “popularized” and not “populated.”

On page 1 the authors write:

You may have noticed something about cryptocurrencies: They don’t do anything. Sure, you can trade them, betting that one will rise or fall, but they aren’t used for anything productive. Cryptos aren’t tied to anything of real value, unlike shares in a company or a commodities future. They’re computer code uncorrelated with any actual asset.

This requires nuance, something the book does not really have.

For instance, not every cryptocurrency is the same. Some, such as non-fungible tokens (NFTs), attempt to represent off-chain assets. A myriad of financial institutions and other large enterprises have attempted to tokenize a plethora of atoms, often in toy experiments that do not last a year or so. However there is an entire category of “real world assets” (RWA) that do in fact represent “real value.”3 We can argue about the particulars – should Paxos USD or PYUSD be allowed to exist? – but the authors cannot ignore the existence of tokenized assets identified by Centrifuge.

A better, a stronger argument they could have used involves “self-referential assets” — which many major cryptocurrencies are considered.

On page 1 they write:

In crypto, this comes from the fees charged by the exchanges, as well as the costs associated with validating the transactions. In Las Vegas, it’s called the rake, the amount the house takes from every pot. This means that, given enough time, the average gambler will lose. It’s how casinos keep the lights on.

I actually agree with one of their points here (regarding opportunity costs) but without evidence it is just another random opinion. A future edition could also cite the musings of Jack Bogle, the founder of Vanguard and creator of the index fund. He often characterized the excessive speculation that benefited financial intermediaries as the “croupier’s take.”

On page 2 they write:

When I first started paying attention to financial markets in the fall of 2020, I came to a similar conclusion, a troubling sense that graft and deceit had penetrated all aspects of the economy, operating with political and legal impunity. It made me want to scream in anger—and to make a wager of my own.

McKenzie is a couple of years older than me and it is hard to imagine how he thinks this helps his credibility.

How can you go your adult life – as someone with an economics degree – without paying attention to financial markets until three years ago? What were you doing in 2008 during the financial crisis? How did you miss the craziness of the ICO boom in 2017-2018 that John Oliver ridiculed?45

On p. 3 they write “crypto-currency” with a dash and then inexplicably use “cryptocurrency” without a dash later. And back and forth. The same happened with the word “block-chain.” Where was the proof reading?

On p. 3 they write:

A few thousand cryptos in 2020 grew to 20,000 two years later, and their purported value swelled in tandem, from some $300 billion in the summer of 2020 to $3 trillion by November 2021.

The authors use this 20,000 figure throughout the book. It comes from reference #4 for Chapter 1 which refers to CoinMarketCap (CMC) but in going to the website, there are currently 9,213 cryptocurrencies.6 For comparison, CoinGecko currently catalogues 10,812 coins. There probably have been significantly more than 10,000 coins or tokens created – many of which have died – but the author’s figure seems like an outlier.7

On p. 4 they write:

Narrative Economics was published in 2019, prior to both the current viral spread of cryptocurrency and the COVID-19 pandemic.

That seems like a weird tie-in especially since there was a mountain of PR for cryptocurrency projects during 2017-2018 in the U.S. For instance, between December 2017 to January 2018, you could turn on CNBC to hear some guest promoting a random coin they liked.8 More than likely, Narrative Economics was published before the viral spread of cryptocurrencies that the authors paid attention to.9

On p. 5 they write:

Two of its biggest drivers were financial deregulation and low interest rates—a decades-long, mostly bipartisan political effort to grow the financial sector combined with a policy intended to stimulate the economy in the wake of the first dot-com bubble.

This is partially true. A future edition should include a conversation around just how leveraged banks were, both foreign and domestic. This would have also been a good spot for the authors to discuss systemically important financial institutions (SIFIs) such as ‘too big to fail banks’ (TBTF) which even Diehl’s book paid lip service to once.

Why are SIFIs and TBTF banks worth discussing? Putting aside the ever present rent-seeking and moral hazard issues, the infrastructure that these organizations rely on often is highly centralized and dependent on a specific vendor thereby creating single points of trust and single points of failure. The book largely ignores legacy infrastructure operated by incumbents.

For example, a future edition could highlight one area the U.S. financial system (specific banks) could be improved: make banks public utilities.

On p. 7 they write:

Coordinating with other countries’ central banks, the US government offered $700 billion in bank bailouts and trillions in loan guarantees, managing to stem the worst of the contagion.

Probably worth telling the readers that this controversial bailout package, frequently referred to as TARP, failed to pass the initial House vote.

On p. 8 they write:

Public key encryption plays a vital role in modern life. For example, all https:// websites (nearly all the ones the average person uses) employ public key encryption. It does things like protect users’ credit card information from being stolen when making online purchases. Public key encryption has two useful properties: Anyone can verify the legitimacy of a transaction using publicly available information (the public key), but the people/parties conducting those transactions are able to keep their identities hidden (the private key).

While this is not a bad explanation, the authors should have used “public key cryptography” because that is usually how it is referred to. In fact, Bitcoin – like most cryptocurrencies – does not use any form of encryption.

On p. 9 they write:

This time-stamped, append-only ledger is the blockchain. In 1991, computer scientists Stuart Haber and W. Scott Stornetta, building off the work of cryptographer David Chaum, figured out a way to timestamp documents so they couldn’t be altered. Each “block” contains the cryptographic hash (a short, computable summary of all the data in it) of the prior block, linking the two and creating an irreversible record, a ledger composed of blocks of data that can be added to a chain (blockchain), but never subtracted from.

This is good. In fact, one of the problems with Diehl et al.’s book is that the trio completely whiffed on the Haber & Stornetta references in the original Bitcoin whitepaper. Worth pointing out that pages later, McKenzie and Silverman reuse this archaic blockchain as a strawman, hold your breath!

On p. 9 they write:

So far so good, but one issue remained: what’s known as the double spend problem. If you remove a centralized authority from the equation, how do you make sure people aren’t gaming the system by spending money that’s already been sent somewhere else? How do you secure the network against manipulation? “Satoshi” relied on what’s called a consensus algorithm.

Pedantically Bitcoin – and its progeny – use what is called Nakamoto consensus. For comparison, Diehl et al.‘s book briefly mentioned it in passing. A future version should incorporate that.

On p. 9 they write:

The network targets a new block every ten minutes or so, by dynamically adjusting the degree of difficulty required in the winning block; the more participants, the harder the process gets, and the more energy is required to guess the next block correctly. This is the proof of work behind Bitcoin: lots and lots of computers (“miners”) performing relatively simple mathematical calculations over and over again endlessly.

This is not really accurate:

(1) There are many proof-of-work based coins. Bitcoin (and some of its clones) have a readjustment period of 2,016 blocks, roughly two weeks. Adjustment does not take place every block as the authors write above.

(2) The resources consumed in a proof-of-work network like Bitcoin rises and falls directly proportional to the coin price. If number go up, then so too does the difficulty level and vice versa. They cite him later in Chapter 5 but it would be helpful to include analysis from Alex de Vries here as well.

What this means is that more energy is not necessarily required to guess the next block correctly. In fact, in its early years, Bitcoin could be solo mined on a normal laptop. Proof-of-work coins that never see much price appreciation can be solo mined by simple computers too.

There is another issue with their statement above: it does not explain the nuance, the difference between a Bitcoin mining pool (which is the block maker) and Bitcoin hashing farms (which generate the proofs-of-work). But more on that later.

On p. 9 they write:

After about an hour, participants in the network are convinced about history six blocks deep; they know that it is extremely unlikely anyone will rewrite that history.

This is not accurate. By social convention – not code – intermediaries such as coin exchanges will allow users to trade their newly deposited bitcoins between 3-6 block confirmations. Centralized exchanges like Coinbase, may require some coins such as Ethereum Classic to have hours of blocks built in order to protect against reorgs. But in both cases, this is social convention, not code.

On p. 9 they write:

As you may be able to tell, Satoshi’s vision is both immensely clever but also cumbersome, practically speaking. As more competitors enter, the hash rate increases and more energy is expended to agree upon a block of data that remains roughly the same size. This is what’s called a Red Queen’s race, a reference to Lewis Carroll’s Alice in Wonderland.

There are a couple of problems with this:

(1) During each transition from CPUs -> GPUs -> FPGAs -> ASICs, whoever was able to access to the newest generation of equipment first has had a material advantage from an energy usage perspective.10 For instance, four pages later the authors mention what Laszlo Hanyecz did – but fail to mention who he is and how he got his bitcoins. Note: Hanyecz was one of the first (if not the first) person to scale bitcoin mining with GPUs. His hashes per watt were likely lower than anyone else up until that point in 2010.

(2) I looked in the refences but do not see the authors point to any article that mention the Red Queens’ race. I myself referred to the Red Queen’s race multiple times in papers and articles between 2014-the present day.11 Would be interesting to see who it originated from (I believe I first saw it on a /r/bitcoin post in 2013); echoes of John Gilmore?

On p. 10 they write:

Ethereum also led to the introduction of NFTs, which are basically links to receipts for JPEGs stored on blockchains (shh, don’t tell that to anyone who owns one).

This is false. Both tokenization and non-fungible token projects existed several years before Ethereum turned on. For example:

Source: ChainLeftist

It bears mentioning that even before Spells of Genesis was released on Counterparty (in 2015) several different colored coin projects attempted to tokenize off-chain assets. See my short presentation on this topic from last year.

In fact, if we are going to be really pedantic, perhaps the original idea behind “crypto art” (and NFTs) was inspired by Hal Finney in 1993?

Source: CryptoSlate

On p. 10 they write:

The number of cryptos exploded around this time, rising tenfold in five years, from less than one hundred in 2013 to more than a thousand by 2017. There are now an estimated 20,000 cryptos, most of them small and insignificant, their ownership concentrated in the hands of a few “whales,” much like penny stocks.

There could be 20,000 coins and tokens, but as mentioned earlier, it is unclear where they arrived at that specific estimate since both CoinMarketCap and CoinGecko currently show around 10,000 each.

On p. 11 they write:

Remember, blockchain is at least thirty years old and barely used by businesses outside of the crypto industry. Since at least 2016, hundreds of enterprises have tried to incorporate it into their business models, only to later scrap it because it didn’t work any better than what they were already using. Ask yourself a simple question: If blockchain is so revolutionary, after thirty years, why is its primary use case gambling? Ironically enough, the more important technology is the one that predates it: public key encryption.

Nearly every sentences in this paragraph has an inaccuracy.

(1) Yes, the “blockchain is at least thirty years old” is really how McKenzie and Silverman are going to spin things. Even if we take their claim at face value the other problem is that not every blockchain is the same.

The Haber & Stornetta “chain” is limited in functionality. What is its throughput? How decentralized is it? Were the authors aware that this archaic chain places attestations once a week in The New York Times? That’s arguably not the best security property.

Source: Twitter

(2) Since there were hundreds of enterprises that have tried to incorporate a blockchain into their business, could the authors provide one example next time?

We are beginning to see a troubling pattern from the authors, lots of strawmen and few specifics.

They could be right, in fact, I even agree with part of their statement. But as Hitchens’s razor states: that which is asserted without evidence can be dismissed without evidence.

What kind of evidence could they have provided?

Source: Twitter

Above is a line chart illustrating Stack Overflow posts per quarter for three different ecosystems: Ethereum, Corda, and Hyperledger (Fabric). The latter two were primarily targeted at enterprises. R3, the major sponsor for Corda, recently announced layoffs impacting more than 20% of the company headcount. Does the decrease in Stack Overflow activity translate to less commercial activity? Maybe.

Since we are already doing their homework for them, here’s another example they could use in a future edition: in the process of writing this review Citi announced that it is offering a pilot service that turns customer deposits into digital tokens, for use use trade finance and cash management. Is this the type of blockchain project the authors think will ultimately be scrapped? Maybe it will, but next edition the authors could give specific examples.

(3) I actually kind of agree with their comment about how popular gambling-type of activities are within the various major chains.12 But strangely, the authors do not beef up their argument by providing any stats or charts.13 Stranger: while there are a handful of graphics in the book, there are zero blockchain-related charts, some of which could have helped strengthen their arguments. A quick googling found a bunch of crypto casino stats. Are the veracity of the numbers reliable? Sounds like something the authors could include next time.

On p. 11 they write:

The original story—that Bitcoin represents a response to the devastating failures of the traditional financial system—holds significant power because we all agree on its premise: Our current financial system sucks. But is the story of Bitcoin actually true? Does it do what it purports to do, create a peer-to-peer currency free of intermediaries? Was a trustless currency relying only on computer code even possible?

I have no affinity for Bitcoin but this is a strawman argument because it uses a retconned narrative from a number of Bitcoin maximalists. Satoshi herself explained that she started coding Bitcoin 18 months prior to the release of the whitepaper, which chronologically places its origin before the financial crisis of 2008-2009. I think the initial motivation was more aligned with securing (and funding) an online poker community, which the authors discuss later in the book.

On p. 11 they write:

Bitcoin may be the most popular digital currency, but it was not the first. In a 1982 paper, cryptographer David Chaum theorized the intellectual scaffolding of blockchain, upon which cryptocurrency would emerge some quarter of a century later.

They do not talk much about “blockchains” later in the book but it is worthy pointing out that in 2023 we typically use an article such as “a” or “the” in front the word blockchain. There was a period of time (mostly around 2016-2017) where consultant-types tried to push an articleless blockchain, but the grammar pendulum has shifted once more.

On p. 11 they write:

DigiCash was a legitimate project, without the conflicts of interest and other red flags surrounding many current crypto ventures. Unfortunately, it failed to take off and in the late 1990s the company declared bankruptcy before being sold.

Who died and made these authors king? By what standard was DigiCash “legitimate” or “illegitimate”? Maybe it was both or neither? But they provide no rubric, just dictum. According to legend, at one point Microsoft considered paying $75-$100 million to acquire DigiCash and integrate into Windows but Chaum wanted $2 per license sold. Also, in 2018 Chaum announced a new blockchain platform, Elixxir. Is this legitimate? It’s a public blockchain so obviously not?

On p. 11 they write about eGold:

It lasted until the mid-2000s before being shut down by the feds for violating money transmitter laws.

Throughout the book the authors describe activities from the FBI but this is the only time they lowercase feds.

On p. 13 they write:

PayPal and other payment services existed, but they were beholden to annoying gate-keepers like the law, national borders, banks, and terms of service agreements.

PayPal provided the MSB-centric model that a couple centralized pegged coin issuers have emulated.

While they make a lot of bluster over Tether LTD, this is the type of statement that impeaches the authors credibility: because neither seems to understand how certain fintechs have skirted U.S.-specific laws they cite in the book. This is nearly identical to Diehl et al. who approvingly namechecks PayPal a couple of times too, all while trying to dunk on “stablecoin” issuers. That is not consistent.

Source: Twitter

On p. 13 they write:

Bitcoin seemed like a solution, but at first no one outside the small Bit-coin network ascribed any worth to its tokens. In a story that has become memorialized in Bitcoin lore

Why is there a hyphen/dash in the 2nd Bitcoin but no hyphen/dash in the other two?

On p. 13 they write:

on March 22, 2010, 10,000 Bitcoins were used to pay for two pizzas, worth forty dollars

Without mentioning his name, or more importantly how he got 10,000 bitcoins, the authors are describing Laszlo Hanyecz. They do cite a relevant Forbes article but I think the readers would enjoy learning how disappointed Satoshi was when she first heard about GPU mining on the Bitcoin Talk forum.

On p. 13 they write:

Sure, the stuff was nearly worthless, but it was open to all, as early adopters could mine Bitcoin with their home computers without racking up enormous hardware and electricity costs.

This is accurate. But it conflicts with a number of their comments on page 9. A future edition should reconcile these conflicting statements.

On p. 13 they write:

Until it was shut down by US law enforcement in October 2013, the Silk Road was the most successful onboarding mechanism in Bitcoin’s history.

This might be true, but how did the authors determine or quantify “the most successful on boarding mechanism”? In looking at the citations and references, there are none. Maybe they are correct but a future edition probably should include a highly cited relevant paper: A Fistful of Bitcoins: Characterizing Payments Among Men with No Names by Meiklejohn et al.

On p. 13 they write:

If it didn’t work as a currency, perhaps a new story could be told. In the coming years, coiners started talking about Bitcoin as a potential store of value (despite its wild volatility) or as the basis of a new, parallel financial system, free of state control.

There are a couple of issues with this:

(1) They include the word “coiners” without providing any definition.14 “Coiners” appears nine times altogether in this book, yet not once do the authors explain what might mean. It is only by looking at the surrounding context that we can guess they have conjured up a word to describe “the outgroup.”

And here is where the story becomes even stranger. McKenize and Silverman arrived relatively late to the coin thunderdome. For some reason, they quickly fashioned themselves as “nocoiners” a term that readers of this blog understand was intended to be a slur. Yet these two market themselves with it as a badge of honor to The New York Times. Bananas.

Recall that the etymology of “nocoiner” arose in late 2017, coined by a trio of Bitcoin maximalists who used it as a slur. I was on the receiving end of coinbros lobbing the unaffectionate smear for years.15 The fact that McKenzie, Silverman and other prominent “anti-coiners” use it as a way to identify themselves – and their “in-group” – is baffling because it is the language of an intended oppressor. Do not take my word for it, read and listen to the presentations from those who concocted it.

If there is one take away from this book: do not willingly use the term “nocoiner” to describe yourself or use the term “coiner” to describe others. It is identity politics.

(2) The authors are somewhat correct: certain Bitcoin promoters, specifically a group that often refers to themselves as “Bitcoin maximalists” did in fact shift the narrative from disintermediated payments to a store-of-value.

Samuel Patterson went through everything Satoshi ever wrote. Unsurprisingly Satoshi discussed payments significantly more than a “store of value.”

Source: Twitter

I do not have a horse in this race, especially since I have no particular affinity for Bitcoin. But I do think the authors should have been more nuanced and specific about who was pushing specific narratives. 16

On p. 14 they write:

This was the beginning of DeFi (decentralized finance), in which tokens would be routed through complex, mostly automated protocols that added leverage and risk to the system—and a chance at huge rewards.

This is the introduction chapter but readers expecting more in-depth nuance will be disappointed because this is pretty much how they describe “DeFi.” It is not really accurate but let us wait a few more chapters to discuss why.

On p. 15 they write:

In late 2020, I came down with a serious case of FOMO. The entertainment business was on ice thanks to the pandemic, and I was bored and depressed. I saw a bunch of average Joes making money in the stock markets, so I dusted off my long-neglected degree in economics and started paying attention to them for the first time in my life.

Look, 2020 sucked for a lot of people. 17 But the statement above does not really help your credibility. Wouldn’t… you want to portray yourself as an expert?

On p. 19 they write:

Cryptocurrencies didn’t do any of these things well. You couldn’t buy stuff with them—the guys at my deli would look at me like I was nuts if I tried to pay for my bagel and coffee in Bitcoin. Advocates say this is a temporary problem; if more people would just buy Bitcoin, eventually it will become a currency you can actually use.

There are at least two issues with this:

(1) Readers have probably noticed the pattern wherein the authors conflate “cryptocurrencies” (broadly) with Bitcoin (specific). This is a strawman. Also, on social media the people who frequently push this particular narrative they are criticizing are often Lightning Network aficionados. Those are a subset of the Bitcoin-specific world.

(2) A lot of cryptocurrency / cryptoasset-related projects are not attempting to tackle payments or reinvent money. According to the book, the authors sample size for “industry events” I believe was just two? SXSW and Bitcoin Miami. That’s not exactly a robust sampling. Sure, you can conduct market research remotely but their unnuanced language has room for improvement.

On p. 19 they write:

The technology behind Bitcoin sucks. It doesn’t scale. Satoshi’s solution to the double spend problem was innovative, but also clunky. The more miners who entered the competition the more energy was used, but the blocks were the same. Bitcoin is able to handle only five to seven transactions a second; it can never go above that.

There are some good criticisms of Bitcoin out there but this rant is just bad, it sounds identical to Diehl et al.

(1) Bitcoin is just one implementation of a blockchain. The authors claimed earlier in this chapter that the “original” blockchain arose thirty years ago. But they never provide any metrics on how fast that one is/was. What is the throughput of the Haber & Stornetta “chain” versus Bitcoin 0.1 in 2009?

(2) The authors conflate the limitations of Bitcoin with every blockchain, and that is intellectually dishonest. There are several different Layer 1 (L1) chains – such as Avalanche – that clearly show the world is not limited to the throughput of Bitcoin. If anything, the omission of other chains shows a lack of market research and due diligence by the authors. Yea, sifting through claims is tiresome work, that’s my day job and often isn’t fun.

(3) Nakamoto consensus (proof-of-work) is not the only game in town when it comes to solving the “double-spend problem.” For just under a decade, different teams of researchers have successfully engineered and productionized proof-of-stake-based chains which overcome some of the limitations that proof-of-work-based chains had. The authors mention “proof of stake” a couple of times later on in passing but do a disservice to readers by effectively ignoring it.

(4) As mentioned a couple of times before: just because someone attempts to mine on a proof-of-work chain does not automatically mean extra resources are immediately required to mine additional blocks. For instance, if I started a new proof-of-work chain tomorrow, a fork of Bitcoin, then a variety of older USB-mining devices could easily generate hashes while consuming relatively little amounts of electricity. Energy (or resources in general) are typically only expended if the coin value goes up. Crab price action is often not attractive miners, especially those who own warehouse facilities filled with hashing equipment.

(5) In the references they cite one paper, On Scaling Decentralized Blockchains, which was presented in February 2016. A lot has happened in the past 7+ years. In fact, the paper primarily focuses on Bitcoin which again, is no the only blockchain in the world. Surely there are more relevant technical papers exploring the challenges and limitations of other chains?

On p. 19 they write:

Visa can process 24,000. To operate, Bitcoin uses an enormous amount of energy, the equivalent in 2021 of Argentina—the entire country. Visa and Mastercard use comparatively miniscule amounts of electricity to serve a customer base orders of magnitude greater. Bitcoin’s energy consumption is enormously wasteful, and poses a massive environmental problem for the supposedly cutting-edge technology (and really, for all of us).

This type of rant is similar to the kind you would find in Diehl et al. book, where there is a kernel of truth surrounded by apples-to-oranges comparisons.

I actually agree with their criticisms of (proof-of-work) energy consumption, and have written about it many times. But their other arguments above are incorrect in at least two ways:

(1) Visa and Mastercard are centralized entities operating centralized infrastructure. In the passage above, the authors endorse and defend rent-seeking incumbents. In the U.S., Visa and Mastercard operate a duopoly that is good only for their shareholders. For instance, following news that the Federal Reserve has proposed lowering the interchange (swipe) fee, the CEO of Mastercard slammed it.18li

The next edition of this book could include a conversation about the friction-filled payment infrastructure that allows private companies to extract rents on retail users in the U.S. For instance, five months ago a bi-partisan bill was introduced in both the House and Senate: “the Credit Card Competition Act, which would require large banks and other credit card issuers with over $100 billion in assets to offer at least two network choices to process and facilitate transactions, at least one of which must not be owned by Visa or Mastercard.”

(2) A better comparison would be between proof-of-work networks (like Bitcoin) and proof-of-stake networks such as Avalanche or Cosmos. The latter two do not require enormous amounts of energy to operate. By continually conflating Bitcoin with all blockchains as a whole, weakens their credibility.

On p. 19 they write:

So if cryptocurrencies weren’t currencies, then what were they? How do they actually work in the real world? Well, you put real money into them and hope to make real money off of them through no work of your own. Under American law, that’s an investment contract. More precisely, it’s a security.

The authors – neither of whom are lawyers – throw this hand grenade towards the end of Chapter 1 and do not even provide a citation in the reference section.19 Maybe they are right, but that which is asserted without evidence can be dismissed without evidence.

Also, anyone can create a (ERC-20) token and pair it with another token on a decentralized exchange, such as an automated market maker (AMM) like Uniswap.20 You can do it without raising external capital from anyone too. That’s precisely what Colin Platt did a few years ago.

On p. 20 they write:

There were now potentially 20,000 unregistered, unlicensed securities—more than all the publicly listed securities in the major US stock markets—for sale to the general public.

You would think they would provide specific examples of coins or tokens, and the facts-and-circumstances as to how they are unregistered and/or unlicensed securities. But they do not. Maybe they are right, but that which is asserted without evidence can be dismissed without evidence.

On p. 20 they write:

Worse, these unregistered, unlicensed securities were primarily traded on crypto exchanges, which often served multiple market functions and, therefore, had massive conflicts of interest.

The first part of the sentence can be correct, but they again do not provide any citation. I whole-heartily agree with the 2nd half of the sentence. I even gave a speech a few years ago, discussing these types of conflicts of interest.

On p. 20 they write:

And perhaps most disturbing, most of the volume in crypto ran through overseas exchanges. Rather than being registered in the United States, they were often run through shell corporations in the Caribbean, apparently to avoid falling under any particular regulatory jurisdiction.

This is a partially valid argument. Although they do not provide specific examples here, anecdotally it is likely that some centralized exchanges attempt to use regulatory arbitrage to avoid specific jurisdictions. But the next edition should provide a couple here (they do a little later).

One other quibble with this passage is that traditional financial institutions do precisely the same thing. They pioneered the playbook of lobbing for regulatory changes and structures in specific jurisdictions. For instance, the entire reinsurance industry is headquartered out of Bermuda.

On p. 21 they write:

When you buy a share of Apple, you are effectively a portion of the revenue stream, as well as the brand equity, market share, intellectual property—all of that. But cryptos don’t make stuff or do stuff. There are no goods or services produced. It’s air, pure securitized air.

This could have been a stronger argument if the authors used nuance. As mentioned earlier, there are “real world assets” (RWA) which tokenize off-chain wares. Instead of making a blanket statement, they should have honed in on the self-referential nature for most other cryptocurrencies. Also, the burden-of-proof is on them when they claim each and every cryptocurrency is a security.

On p. 21 they write about “Dave”:

We came up with a side bet of our own: I bet him dinner at the restaurant of his choosing that Bitcoin would be worth $10,000 a coin or less by the end of 2021. To my mind, it was easy money.

We never find out if Dave is a real person or not but that is unimportant. What is important is that prior to the publication of this book, McKenzie had an undisclosed financial interest: a large bet.21

As another book reviewer pointed out:

In a recent Guardian profile, the actor disclosed he lost as much as $250,000 trying to short the market. Allegedly he got the timing wrong. The article doesn’t share many details, so we can only speculate but this wager could undercut much of what McKenzie has been saying over the years. In other words, the self-declared paid liar is also a hypocrite.

Is McKenzie a liar? He definitely cherry picks but I’m not sure I would use liar to describe him yet. He is definitely inconsistent for not disclosing on social media that he was actively shorting cryptocurrencies.22 Later in the book he kind of defends this behavior by saying he does not invest in public companies so perhaps he justifies it all by claiming the coin projects are private? Again, we do not know exactly what the short(s) were so it is kind of just guesswork.

On p. 23 they write:

I decided to do something. I decided to get stoned.

When I was reading the book, I did an audible chuckle. It may be authentic, but why do the authors think this adds credibility to the story? Why should we take him seriously at this point? This is not the last time we hear about his marijuana usage.

On p. 24 they write:

I needed to do something other than drink to help me cope. Pot did the trick. While high, I stumbled upon an ingenious notion: I would write a book! It would be a book about crypto, fraud, gambling, and storytelling, as told by a storyteller who was himself gambling on the outcome. To my THC-inspired brain, it all made perfect sense. I had stumbled on something profoundly original! The next day, I woke up a bit groggy and realized the obvious: I don’t know how to write a book.

This is not even the silliest thing in the book. By now readers expecting a deep-dive into the nitty gritty should temper their hopes. Easy Money is basically a self-promotion book that takes a serious set of topics and superficially touches on each while giving the authors an excuse to play blockchain tourist. It is a disappointment to those of us who actually filled out whistleblower forms and sat down with prosecutors.

Chapter 2: What Could Possibly Go Wrong?

While every book has an origin story, for some reason the authors felt the backstory for this book was compelling enough to include in the actual book. While there are some amusing parts, most of it should have been left on the cutting board. It all comes across like Entourage wannabes. A good journalist needs a team but that team – and the journalist – do not have to become part of the story. Here they force themselves onto the reader and it is pages that could have otherwise been used to describe more of what happened in El Salvador. For instance, Zeke Faux – and other journalists – show you do not have to continuously insert yourself into the story line just because you have a hot take.

On p. 27 they write:

It was August 13, 2021, and I was perspiring more than I would have liked outside my local bar. It wasn’t the sweltering heat of that summer night making me nervous; it was the stupidity of what I was doing. You know how it goes, what had seemed sensible to propose via Twitter DM after some edibles seemed somewhat less so now. I had invited a journalist I’d never met to pitch him on writing a book I didn’t know how to write about events that hadn’t happened yet. What could possibly go wrong?

If you’re keeping score at home, this is the third time in as many pages that the author mentions he is consuming some form of marijuana. Sure it is just edibles, no big deal right? It is neither classy nor does it add credibility. If anything it reinforces stereotypes of the entertainment industry.

On p. 27 they write about McKenzie’s first interactions with Silverman:

I told him about my econ degree and my interest in fraud. I talked about my friend Dave, and about our little bet that a crypto crash was imminent, and that I felt I had a duty to warn others before it was too late. And then I told him I wanted to write a book about it all.

I genuinely appreciate his sincerity on wanting to warn others but the timing – and self-serving motivations – are ridiculous. Coin prices peak about two months after this meeting. The time to warn, and act, was arguably a couple years before hand. What were you doing in 2018-2019?23

On p. 26 they write:

I could summon my own superpowers as an econ dork and mid-level celebrity and spread the gospel of “crypto is bullshit.” I could call out the liars and thieves, write it all down, and put it out there for the people to see.

This is incredulous.

Pages ago the authors explained how McKenzie had ignored finance until the fall of 2020 and needed to dust off his economics degree. Was the Netflix version of this book going to show a montage of McKenzie pouring over the works of John Nash or Keynes’ General Theory and writing equations on a chalkboard that quickly turn him into an “econ dork?”

To his credit, McKenzie does look a bit like Russell Crowe, so that scene is a possibility.

More seriously: the fact that the authors literally state spread the gospel of “crypto is bullshit” undermines their credibility. How can you be objective while oozing so much self-righteousness? If you are going to self-deputize, shouldn’t you at least go through the motions of ascertaining the facts-and-circumstances like an actual prosecutor must?

On p. 28 they write:

I tried my best to be civil but firm toward my fellow celebrities, some of whom had made a lot more money and had much bigger bills than I did. I get it: Life’s a hustle. But let’s not be gross about it, or lack any discernment or critical thinking. There’s a bridge too far and crypto is past that.

We have no idea how much money the authors made from the book advance but we already saw McKenzie mention he had FOMO and was looking for work. The solution was that he hustled “crypto is bullshit” to anyone including reporters.

For example, last year in that same interview where he wore the “no-coiner” identity as a badge of honor he says:

Trolls still tell me to “have fun staying poor” and I have yet to react by saying “look at my bank account.” That is juvenile.24 And this is not the only time the authors humblebrag.

Chapter 3: Money Printer Go Brrr

This is could have been an interesting chapter, if the authors had spent time explaining to readers how the market structure of the coin world worked. For instance, they could have explained what pegged stablecoins were.25 Who were the major issuers. What market makers were. How centralized cryptocurrency exchanges typically fold together custody, trade execution, and clearing all in one. Instead, we are introduced to a cast of characters that do not seem fully integral to the story (e.g., they are not insiders).

On p. 31 they write:

For skeptics like Jacob and me, there was one corporation that reigned supreme when it came to our suspicions about the cryptocurrency industry: the “stablecoin” company Tether and its assorted entities such as the exchange Bitfinex.

Before diving into this, one thing that was a slight (grammatical) distraction was “Jacob and me” which is used 3 times altogether in the book, versus “Jacob and I” which is used 24 times. Again, not a big deal, just a little copyediting nitpick.

Anyways, much like “coiners,” the authors never define what “skeptics” are. Are they the same as “critics” – another vacuous word they frequently use? Strangely still, they commandeer a word that has been used to describe an assortment of people the past few years.

For instance, I have also been labeled a “realist,” “critic,” “skeptic,” “nocoiner” — oh and a “gadfly.” Terms I have rejected and the authors should have rejected too. For example, on June 30, 2015, CoinTelegraph described me as:

Source: CoinTelegraph

Several years later The Financial Times labeled me as “realist”:

Zeke Faux did not attempt to co-opt a term, his loss, right?

Sure we have “food critics” and “movie critics” but neither of these practitioners deny the existence – or potential utility – of the thing they are critiquing. Over the past 24 months the terms “critics” and “skeptics” seem to be used as a way to market newsletters, podcasts, and books. For instance, David Gerard and Molly White – people the authors namecheck in the Acknowledgements – have built careers out of the “nocoiner” identity – they are fully invested in it. And it shapes their coverage on this topic.

At a minimum can we all agree that fervently marketing oneself something contrarian sometimes devolves into tribalism?

On p. 31 they write:

Founded in 2014, Tether claims to be the first stablecoin ever created. (A stablecoin is a cryptocurrency pegged to an actual currency such as the US dollar.)

Three issues with this:

(1) The authors really should have used “USDT” to describe the token itself and Tether LTD to refer to the company that issues tether tokens. It gets confusing later on.

(2) In a future edition the authors should add a nuance around what a pegged and non-pegged stabilized coin are. For instance, while centrally issued stablecoins like USDT attempt to maintain a pegged value, others such as Rai drift a bit but are relatively stable (due to a controller system and CDPs). There is a small but growing category of assets that are stabilized relative to some external value, by definition they are not pegged-coins.

(3) Back in 2012-2014 during the heyday of “colored coin” projects, there were some toy experiments that attempted to tokenize (link) USD to a discrete amount of satoshi.26 On Counterparty, there was an actual product – Digital Tangible Gold – that tokenized gold held in custody by Morgan Stanley. For history buffs, Pierre Rochard, one of the maximalists who coined the term “nocoiner,” contacted Morgan Stanley directly who then closed the custody account.

On p. 31 they write:

And if you were making huge gains or moving money between jurisdictions, Tether helped avoid the imposition of regulated banks with their pesky reporting requirements.

As previously mentioned it is unclear if the authors are referring to tether (USDT) or Tether (the company). If it is the latter, according to the company they have implemented some KYC / AML requirements. It would be interesting to know how rigorous those were. Also a future edition could explain the difference between banked and bankless exchanges and how USDT acts as a type of shadow bank for latter as well.

On p. 31 they write:

On October 19, 2021, we published “Untethered” in Slate.

At this point I had already interacted with Silverman via Twitter, sending him mining-related links. They reached out to conduct an interview for the article above, here’s what they penned:

Source: Slate

Those were indeed my words, but it does feel a bit like cherry picking for sensationalism. I pointed this out on Twitter too. I also provided a lot of other color that they did not use. Obviously it is their column but I don’t think it was a fair representation of the totality of my conversation.

On p. 31 they write:

We hadn’t cracked the company’s mysteries, but the piece, which built on past investigations by Bloomberg, the Financial Times, and writers like Cas Piancey, Bennett Tomlin, and Patrick McKenzie, was consistent with our proselytizing mission. We were here to ring alarm bells and make sure the lay public could hear them.

This is a little revisionist history and misses some important people such as J.P. Koning. Since the authors have done such a good job at self-promotion, let me give it a shot.

Back in 2017 I introduced “Bob” to reporters including Bloomberg and later the NYT. Bob later went on to speak with the CFTC (this is not to take credit for what became the CFTC lawsuit).27 The most popular post I wrote that year was Eight Things Cryptocurrency Enthusiasts Probably Won’t Tell You which identifies Bitfinex and Tether as the number one glossed over aspect of the ecosystem.

In December 2017, I was quoted in Bloomberg:

“Is there anything backing this?” said Tim Swanson, who does risk analysis for blockchain and cryptocurrency startups. Swanson, also director of research at Post Oaks Labs, said he fears problems with tether could hobble exchanges that trade it. “If these aren’t backed 1-to-1, then what is the contagion risk if one of these exchanges goes down?”

And I was far from the only person curious about Tether in 2017.

While a future edition does not need to cite me, they should at least expand the list of people who openly discussed the role Tether (USDT) played in the coin world beyond the three they mention above, starting with Koning. For bonafides, the oft-cited Money Flower Diagram from the Bank for International Settlements (BIS) specifically mentions Koning’s Fedcoin idea.

On p. 32 they write:

The second red flag for Tether was its size relative to its workforce. Twelve employees (maybe even fewer) are running a business that deals in tens of billions of dollars? Forget the absurdity and ask yourself why. If you were running a legitimate, huge business dealing in big-dollar transactions, wouldn’t you want, and need, more than a dozen people helping you run it?

This would not be a top three red flag for me. The authors are saying: managing that size of money should involve more than a dozen. But does it necessarily? What is the average size of a money manager or hedge fund? According to IBISWorld the average U.S. hedge fund has 10.7 employees.

Ah but Tether LTD is not a hedge fund, or at least should not be, right?

And this is how we arrive at what the top red flag should be and one that Rohan Grey forcefully argues thusly: a case against centrally issued pegged-USD issuers – such as Tether – should be rooted in first principles. Tether LTD intentionally operate as shadow banks and/or a shadow payment provider. Everything else – while perhaps important – is a knock-on of that.

This is why we should put aside conspiracy theories – if Tether LTD owns Evergrande commercial paper – because a first principles analysis would conclude that U.S. regulators should use the tools available to them to bring Tether LTD into compliance irrespective of what Tether LTD has as reserves. If that means Tether LTD is required to form a state or national bank, then that is one (unlikely) outcome.28

However a persistent problem in this book is that the authors spend more time discussing possible hypotheticals rather than what we can easily confirm. The CFTC and NYAG have already provided evidence that backs up the concerns academics such as Rohan Grey previously articulated. Strangely, while the authors namecheck Grey in the Acknowledgements, they do not cite any of his work. A future edition should also include a discussion on shadow banks that explores any similarities between PayPal and Tether LTD.

On p. 34 they write:

They hid that fact from the general public, only to have it revealed with the release of the Paradise Papers, a trove of confidential financial documents that were leaked to journalists in 2017.

It was Nathaniel Popper, then a reporter at The New York Times, who first connected overlapping ownership between Bitfinex and Tether LTD via the Paradise Papers. The reason I highlight this is because Jacob Silverman dunked on Popper on Twitter during the writing of the book. Then later deleted the tweets.29 Despite his stellar reporting on the topic, Popper is notably absent in the book including the reference section.

On p. 36 they write:

To pick one more bizarre factoid from an extensive list, their primary bank mentioned above, Deltec, was headquartered in the Bahamas and run by Jean Chalopin, the guy who co-created the Inspector Gadget cartoon series. If it wasn’t a giant scam, it was at least marvelously entertaining.

In November 2018, I got heckled on stage by a Tether promoter, Josh Olszewicz. Here is part of what he yelled at me from the audience:

Source: Twitter

It wasn’t even the first time I was harassed at a fintech event (John Carvalho stalked me at Consensus 2017).

Putting aside the colorful personalities this space attracts, I still do not understand the Inspector Gadget fascination. 30

On p. 36 they write:

In 2016, Tether was hacked. More than 100,000 Bitcoin (worth $71 million at the time) was stolen, and the company was in desperate straits.

As mentioned at the beginning of this review, this is incorrect. In August 2016, Bitfinex – the cryptocurrency exchange – was hacked and 119,756 bitcoins were stolen.

On p. 36 they cite a paper: Is Bitcoin Really Un-Tethered? by John Griffin and Amin Shams.

But then they wrote something kind of strange in parenthesis:

(Griffin’s blockchain forensics firm has also had contracts with a number of government agencies, indicating that he is advising on crypto investigations.)

Why speculate on what Griffin’s analytics firm may or may not be working on? Surely you could just contact them and ask? It is called Integra FEC.

On p. 36 they write:

Wash trading is the practice of buying and selling an asset back and forth among accounts you control in order to give the appearance of demand for that asset. Crypto is perfectly suited for this sort of manipulation.

To strengthen their argument they could have cited the CFTC settlement with Coinbase before its direct listing two years ago. Its senior engineer, Charlie Lee (who was the creator of Litecoin), was accused of wash trading on the GDAX platform.

On p. 38 they write:

While Tether might have been a last resort for people in need, it carried with it massive costs. Trading in crypto often means incurring heavy fees, and it’s difficult to cash out into real dollars via legal means, pushing people into relationships with unsavory characters who are, at a minimum, not motivated by charity.

How much are those heavy fees?

On p. 38 they write:

In addition, the use of Tether can be seen to further undermine already weak currencies, contributing further to their downfall.

I should be in their small-tent camp, right?

For instance, on November 2, 2018 in an op-ed for FinTech Policy, I labeled Tether (USDT) a systemically important utility for the crypotcurrency world. On March 3, 2021 I gave a presentation to the Fed’s DLT monthly meeting and ended by saying they should look into pegged-coin issuers like Tether LTD.

The authors could improve their arguments by providing specific details because they miss the entire discussion from first principles: centralized pegged-coin issuers acting as shadow banks.

For instance, in their one sentence claim above, how does using Tether (USDT) undermine weak currencies? Which currencies? Is there a nation-state that has adopted USDT? Who knows, the authors do not provide those details.

On p. 38 they write:

I couldn’t believe what I was hearing. On the other end of the line was a male voice I only knew as belonging to a pseudonymous Twitter handle calling himself Bitfinex’ed. He had been on the Tether case for years. Bitfinex’ed had long suspected the company was a fraud, and had paid the price for his obsession with harassment, ridicule, and, he claimed, an attempt to buy him off. On crypto Twitter, some hailed him as a conspiratorial crank while many others, including people in the industry and in mainstream media, had learned to trust his tips.

There are a couple of issues with this:

(1) Bitfinex’ed real name has been in the public for a few years, all you have to do is a bit of googling. It is Spencer Macdonald. How did I find this out?31 Back when I wrote long newsletters he was on my private mailing list and sent me the link to a Steemit article of a guy who “doxxed” him because Macdonald had re-used the same catchphrases “Boom. Done.” under an alias Voogru on reddit.

While the Steemit article mentions his name it is not fully accurate either. At the time, some of Tether LTD’s supporters were pretty bananas online (just look at how one heckled me IRL). For instance, Stephen Palley helped provide legal assistance when there were issues with Macdonald’s Twitter account being locked. CoinDesk ran an article about it.

The other area where that Steemit article is incorrect relates to Jeff Bandman and the CFTC. The entire bottom quarter of that post is a guilt-by-association. Maybe Bandman is bff’s with both Palley and Macdonald, maybe they play golf and tennis together each weekend. There was no evidence presented that they are all in cahoots. Either way, ~2.5 years later we learned the results from the CFTCs subpoenas: that at certain periods of time Tether LTD did not have reserves they claimed backing the USDT (among other things) and some of the executives lied both publicly and privately about that.

(2) What tips did the authors assess were right and wrong?

For instance, Macdonald and I made a bet almost two years ago. And I won. But he blocked me months ago and never sent me the scotch. Sad days.

Source: Twitter

Maybe Macdonald and the group of “Tether Truthers” (USDTQ) are correct, maybe Tether LTD still operates as a fraud today.32 If readers are expecting some kind of “smoking gun” from reading this book, they will be disappointed. Bitfinexed – and some others in his circle – act as if they have some kind of secret knowledge.

When you ask them to simply reveal it, they post to more twitter threads.33 When you ask them to file whistleblower forms, they do not.

For comparison, Zeke Faux met with Bitfinex’ed in-person and wrote the following on p. 77:

When I asked for his sources or evidence, Andrew didn’t have anything new to provide. That was where I was supposed to come in.

[Andrew is one of the nom de plume of MacDonald/Bitfinex’ed]

Nothing secret was revealed in this book which is a disappointment. For instance, Bitfinex is an investor in Blockstream and USDT was directly issued onto Liquid (a quasi permissioned chain operated by Blockstream).34 At least two of the executives, Adam Back and Samson Mow, regularly promote and defend both Tether and the current president of El Salvador. Did they really own a Gulfstream IV?35 Nary a mention of Blockstream in the book.

In my view there are two distinct phases of Tether-related criticism with the divergence before and after the settlements with the CFTC and NYAG:

Phase 1 – concluded in early 2021 where the CFTC and NYAG both proved that Tether LTD did not operate in full reserve and some of the executives lied
Phase 2 – 2021 to the present day, post-settlement Tether Truthers claim that Tether LTD still does not operate and back USDT in full (reserve).

I stand by my previous criticism of Tether LTD and Bitfinex from phase 1.

But the onus is on the Tether Truthers to provide evidence that Tether LTD is still operating as a fraud and/or scam. Maybe it is, but what we typically see on Twitter is innuendo. Are both the CFTC and NYAG missing something? I posted this question on Twitter the other day and was called low IQ. Great feedback, I’ve been called much worse!36

On p. 38 the authors write:

Bitfinex’ed, whose real identity remained a mystery to us

The first search result for googling “Bitfinexed identity” is to a five year old article that links to the Steemit article.

On p. 38 they write:

Despite attempts to dox him—and a temporary Twitter suspension—Bitfinex’ed managed to maintain his anonymity, while developing a growing audience online. His fixation on Tether has bordered on obsession.

Again, the first search result for googling “Bitfinexed identity” is to a five year old article that links to the Steemit article.

On p. 38 they write:

Crypto partisans dismissed him as being salty because he hadn’t gotten in early enough on Bitcoin. But more sober observers pointed out the fact that Bitfinex’ed had been right about many of his claims. Some just took longer to prove.

That could be true, but which specific claims was he right about? Off the top of my head, based on direct communications with him I believe he had two correct predictions:

(1) That USDT was at times not fully backed

(2) That Tether LTD and Bitfinex shared common ownership

And while not a prediction per se, at the time he also transcribed ad hoc interviews that executives, such as Phil Potter, publicly gave on issues surrounding banking access. Speaking of which, did the authors try to reach out to Potter? Because Faux gets a direct quote from Potter regarding the origins of Tether.37

On p. 38 they write:

And few people had done more to educate journalists, critics, and the larger public about the perfidy lurking underneath crypto’s wildly anarchic market activity.

How do McKenzie and Silverman know this? They did not start covering this space until just under two years ago. Did they sit down and tabulate who educated who?

On p. 38 they write:

Bitfinex’ed was the angry, roiling conscience of crypto Twitter, always ready to swoop into a conversation and expose the dark underbelly of the latest industry spin. To some that made him a threat.

Macdonald did not and does not have a monopoly on “exposing the dark underbelly.” For example, did the authors contact ZachXBT?


On p. 42 they write:

SPACs, or Special Purpose Acquisition Companies, were often nothing more than blank checks issued to aggressively self-promoting “investment gurus” who would pocket a huge fee in exchange for gambling with their investors’ money.

This is a good point.38

On p. 43 they write:

My portfolio of short bets was, to put it generously, in shambles. I started with $250,000 that summer, by November it was down to $38,931. While I had bet on other frauds, the main culprit was simple: I had wagered too much on crypto’s collapse too soon, and blinded by my certainty, I nearly lost it all. By the time I got out of my initial crypto positions, they were almost worthless. What had been a lot of money was now very little. To be blunt, it was an unmitigated disaster—the kind of thing that provokes an uncomfortable conversation with your spouse.

We learn a few more details scattered around the book. As mentioned earlier, he began this bet with a friend “Dave” but we are never told its composition. Did McKenzie attempt to short some futures contracts on CME? Also, at least he is honest about his “blinded by my certainty” — something that other book authors on this topic failed to reflect on (such as Michael Casey’s dubiously title: “The Age of Cryptocurrency” reviewed 7 years ago).

On p. 43 they write:

The financial press was practically in lockstep about the inevitable crypto-fied future of money. Politicians, their pockets brimming with donations from industry moguls like Sam Bankman-Fried of FTX, were preaching the Bitcoin gospel. They were also openly contemplating passing industry-written legislation to further legalize these rigged casinos.

This is another decent point. But later in the book, we are only provided a cursory set of examples which we will discuss later. Also, the main quibble readers should have with the 2nd sentence is that the authors conflate “Bitcoin” with “crypto” as a whole. SBF may have been many things, but he did not frequently give off maximalist vibes.

On p. 44 they write:

Since in my analysis crypto was only speculation, it would fall like a rock once the Fed raised rates. Unfortunately for me, I had been just a bit early in making that call.

As my friend Colin Platt – the richest person in the world – is wont to point out: being early is effectively the same thing as being wrong. He says this from experience (with DPactum)!

On p. 45 they write:

In the interests of objectivity—and not wishing to be a participant in the kind of market manipulation I’ve denounced—I’ve never written about the companies I’ve shorted. You don’t have to trust me on this; you can look at my work. I’ve never written about publicly traded companies, only privately held ones. I’ve never traded or owned any cryptocurrency. My bet on crypto was simpler, and bigger than any one company: I thought the whole thing—all $3 trillion of it—was a speculative bubble. That part was obvious to me. The thing I couldn’t prove yet was that it was a bubble predicated on fraud. Hence, my journey with Jacob.

As mentioned above on p. 21, another book reviewer labeled McKenzie a liar and a hypocrite for failing to disclose this bet. The disclaimer above doesn’t really absolve the lack of disclosure: he has a vested interest in seeing the coin world go kaput.

I empathize with McKenzie.

For example, during the rapid rise in coin prices in December 2017, I was quoted as a “skeptic” in The Wall Street Journal:

That was published just days before the Bitcoin price peaked. Yet as certain as I was, I still did not short the market primarily because of counterparty risk and timing. Do I get book deal with Abrams now?

One last comparison, in Number Go Up, Zeke Faux describes a multi-million dollar offer he received to provide some purported Tether-related documents to a short seller. He turned it down, reasoning:

“This book is going to be called Jay Is Wrong and Zeke Is Right: The Cryptocurrency Story,” I said. “As a writer, you don’t want to be compromising in any way, you know? You don’t want to have ulterior motives.”

Unlike Faux it’s pretty clear from the book – and tweets – that at least one author has an ulterior motive: McKenzie discusses his short selling bet a number of times.

Overall this chapter made several interesting observations (such as the abuse around SPACs) but it seems like portions of the chapter could have been removed (e.g., most of the commentary around Bitfinex’ed) and instead re-used to discuss more of the celebrities like Matt Damon who acted as a public spokesperson for crypto-related companies.

Chapter 4: Community

A portion of this chapter hones in on McKenzie’s desire to have an entourage, a crew. It comes across as sappy and cringey and not something a made-it actor or journalist would strive for.39 As mentioned at the top, in no other book on this topic (that I have reviewed) have the writers explicitly stated as much because it should not be necessary.

In fact, because of the never ending drama-per-second the coin world generates, copy-paste Twitter accounts like Web3isGoingGreat, are able to rely on continuous streams of mainstream reportage on this topic to copy-paste from. McKenzie and Silverman did not need a crew of podcasters, and the next edition of the book probably should reclaim these pages to discuss what is going on in say, El Salvador, which was interesting and novel.

On p. 49 they write:

Bitcoin maximalists proudly boast that “Bitcoin has no marketing department,” which is technically true, but in practice dead wrong. Multibillion-dollar corporations—at least on paper—spent real dough to convince people to buy crypto. Sometimes the appeals were explicitly about Bitcoin, leveraging the brand awareness of the best-known cryptocurrency.

While we are never provided a full definition of what “Bitcoin maximalism” or who specifically makes that claim, I have heard this claim before from Andreas Antonopolous during his halcyon days. And while the authors do list off a series of A-list celebrities and entertainers who shilled something coin-related, it would be great to see specific tweets of endorsements in a second edition.

On p. 50 they write:

It also felt appropriate that I found myself on the opposite side of the proverbial line of scrimmage from the Hollywood consensus, but seemingly without a squad of my own. To counter the feelings of isolation and depression in my quest for truth in crypto, I needed to finally meet some fellow skeptics in the flesh. I needed a team of my own. Crypto-skeptic nerds assemble!

You do not need a squad to be a (investigative) reporter in this space.

Sure, building up a reliable rolodex of contacts is part-and-parcel to what reporters covering a beat will accrue over time, but journalists are encouraged not to get too close to sources otherwise you compromise your objectivity.

For instance:

Source: Twitter

I have not had a chance to read Michael Lewis’s new book, but according to his 60 Minutes interview, Lewis still has some affinity for SBF.

Source: Twitter

On p. 51 they write:

HODL is hold on for dear life, meaning that you should cling to your crypto no matter the price.

I have pointed this out in several other book reviews but the etymology, the genesis of “hodl” did not originate as an acronym or portmanteau. It came from a drunk poster on the BitcoinTalk forum, there are many articles discussing this. However, what the authors describe “hodl” to mean is correct.

On p. 53 they write:

Surveying the landscape in 2022, it was hard not to notice the myriad similarities between crypto and pyramid schemes. Both depended on recruiting new believers rather than buying anything with an actual use case.

This is an adequate comparison (for many cryptocurrencies).

I currently think a decent description of Bitcoin itself is how J.P. Koning categorizes it as a game akin to a decentralized chain letter:

Source: J.P. Koning

On p. 54 they write:

Bitcoin ownership is highly concentrated in an extremely small number of whales who wield enormous power in the highly illiquid market. According to an October 2021 study conducted by finance professors Antoinette Schoar at the MIT Sloan School of Management and Igor Makarov at the London School of Economics, .01 percent of Bitcoin holders control 27 percent of all the coins in circulation. Some community.

Anecdotally this is probably true, for Bitcoin at least. Is it the case that every cryptocurrency / asset is the same way?

On p. 54 they write:

The eccentric community of crypto skeptics also fits in that category, and I was proud to call myself a member.

We are over 50 pages into the book and the authors still have not provided a succinct definition of what a “Coiner” or Skeptic” or “Maximalist” or “Critic” are. What are these tribes? What are their etymology?

On p. 56 they write:

many coiners really do feel that they are part of a like-minded community

What are coiners?

On p. 56 they write:

Practically everyone I spoke to at crypto conferences and other public events both admitted to being scammed and accepted it as if it was almost obligatory, a character-building exercise and bonding agent. Few spoke about stopping scammers in general.

This is a really good point, and I completely agree with the authors.

McKenzie’s experience reminded me of the meme from The Ballad of Buster Scruggs:

It is still unclear why this rugging behavior is perceived as a rite of passage and normalized.

On p. 57 they write:

In the case of the 20,000 cryptos other than Bitcoin, it should be simple to categorize them under the law. Most were securities made by real companies with real employees.

Maybe that is true, did the authors cite a securities lawyer? Did they quote a U.S. judge?

This is the same problem that occurred in Diehl et al., book: lots of opinions but few references. I am a certain there are U.S.-trained lawyers who share the same views as the authors, why not quote them here? For instance, later in the book they chat with John Reed Stark; this would have been a good spot to introduce him.

On p. 57 they write in parenthesis:

Ethereum also used proof of work to mine its cryptocurrency, until turning to proof of stake in September 2022. In proof of stake, owners of the crypto validate the blocks, making the system far less energy intensive, but incentivizing even more centralized ownership.

Two issues with this:

(1) As mentioned earlier, while there is some discussion of proof-of-work-based mining (the authors visit a hashing farm in Texas), the conversation or discussion around alternatives — such as proof-of-stake — are few and far between.

(2) Did the authors provide evidence that proof-of-stake systems are even more centralized? Maybe they are, but no references were provided. What can be asserted without evidence can also be dismissed without evidence.

This also reminds me of Matthew Green’s evergreen tweet:

Source: Twitter

On p. 57 they write:

What started as simple speculation and peer-to-peer exchange became a web of derivatives markets, DeFi protocols (a set of rules governing a particular asset, often using so-called smart contracts, run on blockchains), lending pools, and other newfangled features of digital finance.

What are derivatives markets? What are DeFi protocols? What are lending pools?

On p. 58 they write:

Under this arrangement, buying Dogecoin on a crypto exchange like Binance was indeed an act of trustlessness, but only in the sense that it was hard to trust any offshore crypto entity.

This is a strawman. Why? Because Binance is a centralized exchange, it is a trusted-third party. No one is arguing that Binance or other centralized exchanges are… decentralized.

On p. 58 they write:

“Not your keys, not your coins,” was the mantra thrown around by die-hard crypto fanatics, meaning you should keep your crypto in a “cold wallet” that didn’t touch an exchange—or even the internet. But that kind of advice did not reflect the reality of the markets. It defeated the primary purpose of money, which is to make buying and selling stuff convenient and fluid.

I mostly agree with their observation and have written about all of the “friction” that coin-related intermediaries often add. But there does need to be a nuance with private keys because various controllers in traditional finance also have key (recovery) management involving hardware wallets, cold wallets, an so forth. Traditional finance has incorporated the modern iteration; see Thales on slide 9.

On p. 58 they write:

Unfortunately, creating money that’s trustless is impossible in practice, for it goes against the very nature of money itself. Adopting it as a mission can only lead to disappointment.

There are a couple issues with this:

(1) This seems to be an a priori argument. By definition, a priori arguments are the opposite of empirical arguments. So no matter what evidence someone could provide, it seems like the authors have made up their mind.

(2) Not every cryptocurrency or cryptoasset project is attempting to reinvent money.

On p. 59 they write:

In the United States, the nation with the largest economy in the world—as well as the issuer of the world’s reserve currency since 1944, the US dollar—we often take this consensus for granted. Everyone wants dollars, especially in times of crisis.

What is a reserve currency?

There are several reasons why the U.S. is the issuer of the world’s reserve currency. While the authors do mention a couple of authors, experts such as professor Michael Pettis and Brad Setser, attribute the U.S. dollars current reserve status due largely to the (im)balance of trade. The U.S. runs large trade deficits. And mercantilist economies such as China are either unwilling or unable to shift to running large trade deficits. Until something dramatically changes, the U.S. dollar will continue to remain the key reserve currency.

On p. 59 they write:

In that sense, the stated goal of cryptocurrency—to create a trustless form of money—is literal nonsense. You cannot create a trustless form of money because money is trust, forged through social consensus. As Jacob Goldstein writes in Money: The True Story of a Made-Up Thing, “The thing that makes money money is trust.” Saying you want to create trustless money is like saying you want to create a governmentless government or a religionless religion. I think the words you are searching for are anarchy and cult. The bartender should cut you off and make sure you get a ride home.

This is a strawman. Not every cryptocurrency or cryptoasset project is attempting to become “money.”

There are a number of coin promoters who regularly echo comments similar to Zero Hedge, that the U.S. dollar is doomed. Maybe it is, and maybe that is who the authors are thinking about, but we are not provided specific names of people who make the argument that a specific cryptocurrency is going to become a “reserve currency” let alone “money.”

On p. 60 they write:

The failures of our current system to do so have no doubt lent the story of cryptocurrency much of its power. A severe, and very understandable, lack of trust in the financial system reflects a wider loss of faith in democratic governance. Wealth inequality is at near record highs and many working people feel that the economy is rigged against them. But that doesn’t mean the story of cryptocurrency is true, or offers a better alternative to the present situation. You cannot replace people and flawed institutions with magical bits of computer code.

There are a couple of issues with this:

(1) What are some of the failures of the current system? Are the authors referring to too big to fail banks? Systemically important financial institutions?
(2) What is the story of cryptocurrency? Which one? This is a problem with generalizing without looking at the facts-and-circumstances of each.

On p. 60 they write:

That code was written by human beings who themselves are far from perfect.

This seems like an inconsistent argument. Is the claim that “smart contracts” and/or “blockchain” projects are inherently prone to error because humans wrote the code? If so, shouldn’t we be equally concerned about all digital, automated financial infrastructure created by humans? Why single out cryptocurrency?

On p. 61 they write:

A decentralized financial system seemed less like an inherently noble pursuit than an alternative structure that, just like TradFi, further enriched those at the top.

What is TradFi? They tell us later but should have mentioned it here.

On p. 61 they write:

I will inevitably be attacked by crypto promoters as advocating for nation-state supremacy or excusing the myriad failings of this or that government, but that is missing the point entirely.

In the past I have jokingly referred to myself as a statist shill. Looks like we all could have been fellow travelers at some point!

On p. 61 they write:

Consider a familiar example: our banking system. Why do you trust that the money you put in a licensed US bank is going to be there when you want to use it? Because the federal government guarantees it in the form of the FDIC (Federal Deposit Insurance Corporation).

While true this seems a bit of cherry-picking because we also have too big to fail banks that are regularly penalized for screwing their customers. I think there are better arguments to describe the utility of trust that has been created by public institutions like the U.S. Mint or the Federal Reserve without having to describe prudential regulators such as the FDIC.

For instance, earlier this year Bank of America agreed to pay $250 million in fines and compensation to cover “junk fees” it had levied on customers. Last December, the Consumer Financial Protection Bureau (CFPB) fined WellsFargo $3.7 billion for rampant mismanagement and abuse of customer accounts.

On p. 61 they write:

Is our financial system perfect? Of course not! In fact, it is deeply, deeply flawed. It cries out for more reform and democratic accountability. But it at least includes guardrails that protect consumers and a legal framework that acknowledges the role of trust in binding people together, whether in social life or commerce.

There has got to be a better way of defending “trust” and “consumer protections” than defending private incumbents.

That passage also sounds strikingly similar to what Diehl et al., wrote in their own book:

While our existing financial system is undeniably profoundly flawed, not optimally inclusive, and sometimes highly rigged in favor of the already wealthy; crypto offers no solution to its problems other than to create an even worse system subject to unquantifiable software risk, profound conflicts of interest, and an incentives structure that would exasperate wealthy inequality to levels not seen since the Dark Ages. Put simply, Wall Street is bad, but crypto is far worse.

When I tried to explain to friends that this book unnecessarily carries water for incumbents, this is the reoccurring meme that came to mind.

There is no reason the authors have to defend incumbents or the a cartel that regularly is fined for the very activities that the authors abhor. Guess who invented all of these criminogenic concepts in the first place?

Rather, it is possible to critique both the coin world and the traditional financial world. You do not have to join one camp or the other.

On p. 62 they write:

But nonetheless, the private banking era was not a success, and eventually central banks were created to better manage the franchisee banks and ensure the safety of customer deposits.

Agreed, and there is a long line of commentators, researchers, and academics who favor policies allowing retail to directly gain access to central bank money (bypassing commercial banks). 40 There is no technical reason, in 2023, for retail to be intermediated from central bank money. If this comes in the form of a central bank digital account and/or digital currency is a separate discussion and one worth having.41

On p. 62 they write:

Among the many butcherings of language in cryptocurrency, historians may find this the cruelest cut of all. The purported “future of money” is in fact the past of money, a failed experiment and one we revisit at our collective peril.

At least two problems with this:

(1) It generalizes all cryptocurrencies as attempting to build a “future of money” when this is not the case.
(2) It is an a priori based argument so by definition it is not evidence-based.

On p. 62 they write:

I have to address one last false story that Bitcoin maxis—the people with the laser eyes who aren’t Tom Brady—have been spreading.

That is a shallow explanation of a Bitcoin maximalist. While some prominent maximalists may have added laser eyes to their profile pictures, that’s more of a degen meme than anything else. Many of the original Bitcoin maximalists – the guys and gals who coined the term – hate me and made it abundantly clear on Twitter each quarter from mid-2014 until the present day. They did not have laser eyes until the past couple of years.

On p. 63 they write:

In economics, supply does not determine scarcity. Supply is simply the amount of something available to be bought or sold. Scarcity occurs only when the demand for that thing exceeds the supply at the price of zero.

I whole heartily agree! This is a good point.

On p. 63 they write:

Imagine I own the rights to all the dogshit in Brooklyn. I have approached each and every dog owner in the fair borough, and they have agreed to sell me their dog’s poop. I do not own the dogs, mind you, merely the rights to their fecal matter. Now, there are only so many dogs in Brooklyn, and there is only so much they can defecate. The supply fluctuates by the number of dogs—despite how it may appear, there is an upper limit here on the number of dogs, certainly lower than twenty-one million—and the amount of times they poo. But is dogshit scarce? Are people clamoring for it because it is prized and useful? Will my cornering the market make me a rich man? Unfortunately for my empire of shit, the answer to all those questions is no.

Much like smoking pot and consuming edibles earlier in the book, is it really classy to use this specific example? Surely there are less crude ways of explaining supply and demand?

On p. 64 they write:

By now, more than 90 percent of the Bitcoins that can ever exist have already been mined. That makes Bitcoin’s supply almost perfectly inelastic, a fancy word meaning it can’t grow or shrink in response to changes in price.

The fact that over 90% of bitcoins total supply has been mined is not why bitcoin is perfectly inelastic. What makes it perfectly inelastic – a topic I have written on a few times before – is that fact that irrespective of the labor force applied, no extra units of bitcoins can be extracted. With proof-of-work networks like Bitcoin, the marginal productivity of labor is zero. It does not matter how many more units of labor are added to the income generation (mining) process as the network will always produce the same amount of economic output. In contrast with traditional commodity extraction, deploying more equipment or a larger labor force, could result in large production of say, a precious metal.

There is one caveat: Bitcoin mining may be considered perfectly inelastic due to the code that prevents extra units from being extracted, but the way block propagation works in practice, block makers (mining pools) have accelerated halvenings.42 That is to say, when Bitcoin was first released, the halvenings were expected to coincide roughly every four years. However because of how mining works in practice, the next halvening is expected April 2024, about 8 months ahead of schedule.

On p. 64 they write:

It’s basically fixed. This makes the price of Bitcoin even more susceptible to changes in demand.

Agreed! I – and several others – have written about this before.

On p. 65 they write:

The problem with the Bitcoin-as-digital-gold argument runs even deeper when we examine economic history. Bitcoin maxis are often “gold bugs,” meaning they want us to return to the gold standard, when you could exchange paper money for a certain amount of gold.

Anecdotally this seems to be true, many maximalists I have met and/or interacted with often are some form of goldbug.

On p. 65 they write:

But elasticity is crucially important in times of crisis.

Agreed!

On p. 66 they write:

But that does not mean returning to the gold standard would be any better.

Agreed!

On p. 66 they write:

The day after the Super Bowl, I finally met in the flesh my first fellow crypto skeptic not named Jacob Silverman. Cas Piancey and Bennett Tomlin host a podcast called Crypto Critics’ Corner that proved a lifeline when I first stumbled into the seemingly lonely world of crypto skepticism in the spring of 2021. Sensing something was off about the industry but hoping to educate myself, I searched for decent podcasts on the subject.

(1) I am not going to say do not listen to their podcast, but McKenzie is correct: it was (is!) hard to find a good podcast that isn’t 100% shilling the listener something. Can recommend Epicenter which regularly hosts technical-focused guests. And despite my disagreements with her in the past, I think Laura Shin’s Unchained is often quite good too. For instance, here is her recent interview with Zeke Faux.

(2) How did McKenzie conduct a “literature review” or due diligence during 2021? Although tough to navigate, there were plenty of active “skeptics” or “critics” that the authors never even mention, such as Mark Williams, Yakov Kofner, Angela Walch, and J.P. Koning.43 We will discuss this again later.

On p. 68 they write:

Appearing on Crypto Critics’ Corner alongside Jacob, who joined remotely from Brooklyn, would mark my first long-form interview in my bizarre career pivot. Cas, a sideways-baseball-cap-wearing SoCal native, welcomed me generously, showing me around the studio owned by an artist friend whose elaborate wood carvings decorated the walls.

It is unclear why the authors are using this nom de plume when Cas Piancey revealed his identity last year. His real name is Orson Krupnick Newstat.44

On p. 69 they write:

Leaving Cas’s studio, I realized I had found my community. It had nothing to do with a coin we were pumping, a company we believed in, or some utopian technological vision that, in practice, came with a heavy side of dystopia. We wanted to understand this crazy new financial system, especially its dark side. And it helped that we liked each other.

This book seems like it is veering into auto-biography territory, was that the intent?45

On p. 69 they write:

The crypto skeptic community that Bitfinex’ed, Cas, Bennett, Jacob, and others brought me into became my team, friends, and trusted colleagues. A few of them I regarded as heroes—or at least the closest thing to it in an industry in which it seemed most people would sell a Ponzi scheme to their mother if it would help pump their bags. Bitfinex’ed—whoever he was!—was our initial ambassador to this new community, but he was soon joined by other pseudonymous online sleuths, as well as economists, computer scientists, indie journalists, cynical former bankers, straight-laced former regulators, stoner podcasters, Scandinavian businessmen, and a few untrustworthy cranks.

Maybe this is one “crypto skeptic community” but certainly not the only one. Also, for years I have been referred to as a “crypto skeptic” — a title I thought was shallow and one I never adopted. Does this make me a crypto skeptic, skeptic? Crypto skeptic skeptics, assemble!

On pgs. 69-70 they write:

To say I learned a lot from them would be a vast understatement, and it quickly became apparent to me why a community like this was valuable. The world didn’t need just one crypto critic, it needed a thousand of them, of diverse backgrounds, interests, and motivations, spelunking through the industry’s darker corners and sharing what they found. When everyone was selling something, we needed a few people to say, “I’m not buying, but I’m curious how you do it.”

Apart from the fact that the authors still do not define what a “critic” is or is not, I agree with nearly everything in this statement. With one major caveat: let’s try to forego purity tests, especially if you just became interested in this space. See for instance, this clique of “no-coiners” acting as if there wasn’t a wider universe of coin “skepticism” or “criticism.” Let’s be Big Tent and include actual technical experts, not just people we may agree with.

On p. 70 they write:

At least now, with Cas, Bennett, and a delightful crew of eccentrics behind me, I had a corner of my own to retreat to in between rounds. Admittedly, it was a David and Goliath battle—a random group of skeptics up against a multi-trillion-dollar industry. But I came back from Los Angeles with more pep in my step. Maybe it was just the gambler in me, but I liked my chances.

Repeating it over and over does not make it sound more objective. Readers might ask: are you moonlighting as a reporter or as a social club manager? Can’t be both. Plus, there are a number of investigative reporters operating at this point, did you reach out to any of them for potential collaboration?

Chapter 5: SXSW, the CIA, and the $1.5 trillion that wasn’t there

This chapter should have been split into two, with the visit to the Bitcoin mining facility pulled out. Also, because of the uneven tone of the book up until this point, it wasn’t clear who the authors felt would narrate this in the movie adaptation. You might think think this is facetious but the entire conversation with the alleged CIA agents does not give a reader any sense of conclusion, there is no bowtie on it. What purpose do the agents fill besides page filler?

But let’s start with one of the two events they attended.

On p. 71 they write:

In early 2022, South by Southwest (SXSW), a big tech and music conference in my hometown of Austin, Texas, invited me to organize a panel of crypto skeptics. I was pretty fired up. SXSW would mark our first venture into the real world; everything Jacob and I had done thus far was online or remote. We recruited Edward Ongweso Jr., a razor-sharp journalist for Motherboard, Vice’s technology site, to join us on stage. I decided to record the whole thing, hiring a local director of photography, Ryan Youngblood, to film whatever hijinks might transpire.

What are crypto skeptics? Are they the same thing as critics or realists? Why did they choose Ongweso?

On p. 72 they write:

“Well, there’s another DAO that helps with that,” he said. His dream was to move to Portugal, a burgeoning crypto tax haven.

That was probably true while the book was being written, however in October 2022, the Portuguese government said it will start taxing short term gains on digital assets. It is unclear if this has reduced the desirability or appeal for crypto-related projects from domiciling.

On p. 73 they write:

Bad actors are everywhere—certainly in so-called TradFi, or traditional finance—so why should crypto be different?

Ah, gotta love the “so-called” modifier. While the authors do interview a number of coin promoters and coin “skeptics” they don’t make much room for anyone who works in traditional finance. Strange because there are credible people within the world of “tradfi” that probably agree with their views. A second edition should interview experts at the DTCC (the largest CSD in the world) or say, Tony McLaughlin from Citi, he’s no coin shill.4647

On p. 75 they write:

The guy who had approached us, whom I will call Charles, led us over to a group of six people with SXSW name tags that read USG in the spot reserved for their employer. Most of them were unassuming: close-cropped hair, dress shirts, fleece vests—the typical uniform of law enforcement people playing at casual dress.

For approximately four pages the authors describe a strange interaction they have with a couple of alleged spooks.

For example they write on p. 76:

Charles was a couple years from early retirement. “I can’t wait to smoke weed!” he said. “It’s great,” we assured him.

Yet more weed smoking by the authors. Why is this in the book?

On p. 78 they write:

“You need to be a borderline sociopath to do this work,” Charles said. “Ryan is probably too normal,” he added, referring to our local cameraman, who said he had been rejected years earlier from the CIA. Ryan smiled uncomfortably.

It was never fully clear why the authors hired a cameraman for many of their interviews. Are they planning on releasing a video as well? For instance, last year Alex Gladstein asked the authors to release the video interview of SBF, which they declined.48

On p. 78 they write:

It went like this all night, Jacob and I exchanging occasional looks that indicated our mutual disbelief. At one point, Jacob gawked as Charles explained that the NSA had found “a small bug” in Signal—the encrypted messaging app used by journalists, activists, and millions of other people, including the spies at our dinner table—but if you restart your phone once a week or so, it wasn’t a problem. It was hardly a sophisticated technical explanation, and maybe it was all bullshit braggadocio, but a Signal exploit would be incredibly valuable—easily seven figures on the open market—and a closely held secret by any intelligence agency.

In my typed notes on Kindle I wrote “Isn’t this burying the lede?” Surely a big story here is that a U.S. intelligence agency used an exploit in Signal?

The only reason I can think of not to include this earlier is because we never learn if these two people – Charles and Paul – actually were spooks. I’ve met people at conferences who claimed to work for a branch of the government and I would google them afterwards and often it was true. What did the authors find out about these two?

On p. 82 they write:

There are more than 20,000 cryptocurrencies out there, sophisticated exchanges, decentralized finance protocols that allow billions of dollars of crypto to change hands without human intermediaries, and financial products that resemble less regulated, riskier versions of their Wall Street equivalents.

What are sophisticated exchanges? What type of decentralized finance protocols? What are human intermediaries? Which financial products resemble less regulated, riskier version of their Wall Street equivalents? It is unclear.

On p. 82 they write:

At least in the gambling-like realm of financial speculation, there’s a lot you can do with crypto. With few guardrails in place, it’s easy to borrow money and add leverage in order to increase one’s odds of winning big or losing everything. Many of these financial products and transactions are extremely complicated, and difficult for the average investor to navigate. Nearly all of them are extraordinarily risky.

I agree with the majority of these comments apart from the leverage element. At the time it was written leverage in the coin world was primarily procured by going through a centralized intermediary like an exchange (Binance) or lender (Celsius).49

On p. 82 they write:

By some measures, Celsius was a successful going concern, but with investment backing from Tether (they loaned Celsius over $1 billion), strange lending activities, sky-high interest rates on offer, and some murky movement of its tokens, it was an object of extreme speculation and rumor within the crypto-skeptic world.

If there is a second edition the authors must cite Maya Zehavi for being the first “Celsius skeptic.” Among other firsts, she was the first person to publicly put a magnifying glass on Hogeg before and after he was removed as CFO. Is she a “skeptic”? She was often labeled as one before the term was co-opted.

On p. 83 they wrote:

I took a breath, told myself that I wasn’t hungover from a night of drinking with CIA operatives, and, trailed by my cameraman, did my most confident walk over to Mashinsky and his confederates.

But were they actual spooks? Is the reason Charles and Paul were in this book just so the authors could say they drank with some alleged spooks?50

On p. 84 they wrote:

We got it on camera. There were moments that astonished me. Talking about scams, he took the usual tack and said people needed to educate themselves.

So are you going to release the video too? Seems spicy no?

On p. 84 they wrote:

Toward the end of our conversation, when the video was off but with audio still rolling, Mashinsky told me something that made my blood run cold. I asked him how much “real money” he thought was in the crypto system. I didn’t think he would actually answer the question, but he did.

Is that common? To turn off the video but keep the audio rolling? I have no affinity for Mashinsky but was that an accident?

On p. 84 they wrote:

“Ten to fifteen percent,” Mashinsky said. That’s real money—genuine government-backed currency—that’s entered the system. “Everything else is just bubble.” The number seemed straightforward and eminently believable. But it was still shocking to hear it from a high-level crypto executive, who seemed totally unconcerned about it all. Mashinsky acknowledged that a huge speculative bubble had formed. If the overall crypto market cap was about $1.8 trillion at the time we spoke, that meant that one and a half trillion or more of that supposed value didn’t exist.

Everyone new to this space is entitled to be shocked, that the “market cap” is probably not an actual “market cap.”

For instance, five years ago, I cited an estimate from Nikolaos Panigirtzoglou at JP Morgan entitled “Flows & Liquidity: The emergence of cryptocurrencies.”  According to his analysis:

The net flow into cryptocurrencies is very much a function of coin creation which is controlled by computer algorithms and in the case of bitcoin is diminishing over time. Figure 6 shows the net amount of money invested every year since 2009. The cumulative amount has totaled around $6bn since 2009, well below the current market cap of $300bn.

Panigirtzoglou illustrates this over time with the bar chart below:

Around the same time Citi published a note with similar estimates:

In 2017, cryptocurrencies grew from a market cap of less than $20bn to around $500bn. We estimate this surge was driven by net inflows of less than $10bn.

What was the estimate five years later?

That’s a good question and something the authors do not readily provide an answer for apart from citing Mashinsky and later SBF. Maybe the two operators are/were correct but definitely a missed opportunity and one that should be included in another edition.

Graph 1 (above) comes from Project Atlas, a new initiative coordinated by the BIS in partnership with several other central banks. Figure C is likely something the authors would find of interest.

On p. 84 they write:

And given the general lack of liquidity in crypto markets—that a billion dollars’ worth of Ethereum isn’t redeemable for a billion dollars of cash without tanking the market—that meant that the crypto economy was dancing on a knife’s edge. One bad move by a major player might tip the industry into freefall. An illiquid market based on irrational speculation, it was all essentially vapor.

Well that could be true, what references did they cite? Nothing in the works cited at the end. That which is asserted without evidence can be dismissed without evidence.

On p. 85 they write:

Crypto critics call it “hopium,” and it’s a powerful drug.

What is a crypto critic? Who was the first crypto critic to call it hopium? It might actually be difficult to identify because there is a French automobile brand called “Hopium” founded in 2019. I believe the first time I heard the term “hopium” as it related to coins – was after the 2017 bubble imploded. People were making memes of “copium” and “hopium” but perhaps I am misremembering and it was more recent.

On p. 85 they write:

As OG crypto critic David Gerard would say, “You lost your money when you bought the tokens.”

Gerard may have said that and he might be right but let’s not hand over trophies to people who market themselves as “crypto critics” or call someone an “OG” when they are not.51

Whose shoulders did Gerard and others stand on? In addition to J.P. Koning and Angela Walch (mentioned before) there was Ray Dillinger. If we were to make a chronological argument, then a “godfather” of ‘crypto critics’ (in the English-speaking world) is professor Mark Williams. Who is Williams?

Williams’ op-ed appeared about 6 days after the price of bitcoin peaked. Despite arcuately describing its volatility, some Bitcoin promoters labeled him “Professor Bitcorn.” Why wasn’t he mentioned in this book?

In April 2014 Williams even provided public testimony at a U.S. House committee. Definitely worth referencing in the next edition.

And since we are being very specific, if the authors really wanted to label something “OG” then we might want to hand a trophy over to the annual Financial Cryptography and Data Security conference whose attendees include a crossover from the cryptocurrency and blockchain world (remember, “crypto” used to mean “cryptography.”) What kind of crossover? Just look at the 2023 program.

Inexplicably the authors continue this chapter and include an unrelated topic: a visit to a Bitcoin mining facility.

You know what is a tad weird? The authors are about to visit the largest U.S. based Bitcoin mining facility – operated by Riot Blockchain – and they miss the opportunity to speak with Pierre Rochard. Yes, that Rochard – the co-creator (popularizer?) of the “no-coiner” pejorative works for Riot. In fact, Rochard hasn’t missed a beat, pushing out nonsense that is indistinguishable from satire (he’s the one walking in a field with a hard hat).

On p. 85 they write:

If you drive for about an hour northeast from Austin, past the scrub brush and the quota-driven traffic cops, you reach a former Alcoa aluminum smelting plant on the outskirts of the tiny town of Rockdale (pop 5,323). It was the kind of old-school corporate holding that’s so big they built a lake to service it (Alcoa Lake). The facility, sold in 2021 for $240 million to an obscure real estate firm, had mostly gone fallow. But its mere existence—the mothballed warehouses, silent smokestacks, miles of fencing, the power substation on site—was a reminder of a not-so-bygone era when large industries operated in the United States and factories, perhaps even staffed by decently compensated union workers, actually made stuff.

This is good prose, this part of the chapter is pretty good. Readers deserve an entire chapter – heck, a whole book – discussing the zaniness of the mining world. For instance, Riot earned $31 million in energy credits from ERCOT (the energy regulator in Texas) in the month of August. That is right, a Bitcoin mining company got paid not to mine. This isn’t a brand new subsidy either and it deserves (ridicule!) mention in the next edition.52

Continuing on p. 86 they write:

Money was coming in, ambitious building projects were planned, people were getting steady construction work—all the supposed hallmarks of basic economic progress. But to what end and at what cost? I had come to Whinstone to find out, accompanied by Jacob and David Yaffe-Bellany, a reporter from the New York Times who wanted to write a piece on me.

We never did find out to “what end” or “what cost” — we are left wondering. We have seen a widely circulated video inside one of the Riot’s facilities so that gives us some idea of how large, but the authors should have provided an answer to these. Also, was that a humblebrag?

On p. 87 they wrote:

We wanted to hear their pitch: how Bitcoin mining brought jobs, stimulated development, and would be an asset for the whole community. To hear that pitch, they asked us to sign what amounted to nondisclosure agreements. David, the Times reporter, assured us that he couldn’t, his job wouldn’t allow it. None of us felt comfortable. What was the point of signing something that might limit our ability to write and report on what we might see? It made no sense to do so when we were going in with cameras—if they were going to let us in with cameras.

Oddly enough, we as readers, never did get to hear that pitch described in words even after the authors did not sign the NDAs. What are the jobs numbers?

On p. 87 they wrote:

Eventually we confronted a more urgent reality: Jacob really had to pee. Standing practically cross-legged outside the car, his face radiated the barely withheld anxiety that comes after a long car ride after a morning guzzling coffee. I was a bit out of sorts, too. We were supposed to be featured in the New York Times as intrepid crypto critics, and here we were unable to get into our featured location while self-urination seemed to be a non-zero possibility.

Look I was born and raised in Texas, spent about 25 years there. And I fail to see how this passage is interesting. It’s like the marijuana consumption, probably should cut it out.

On p. 87 they wrote in parenthesis:

We’d met a lot of strident Bitcoin critics but not anyone interested in attacking a Bitcoin mine.

Well at least this time the authors provided a little nuance “Bitcoin critics” and not just “critics.” And if we were to guess why the site has the security measures described it is likely because Riot doesn’t want someone to come in and steal the mining (hashing) gear. Those are effectively money printers. The golden goose as it were.

On p. 88 they wrote:

We chopped it up for a few more minutes, and then, after the typical alchemy of bureaucratic authority parceling out permissions, we were told that we could go in the gates and drive to the main office. “I left my NDA in the bathroom,” said David as soon as we piled into the car. Jacob announced his paper was under his foot. Others had disposed of theirs quietly in their pockets. Either some Whinstone official had forgotten about the agreement during our time in the office or perhaps had been overruled. It didn’t matter. We weren’t signing anything. They waved us through the gate and we drove in.

I am not a huge fan of NDAs but I have signed my share of them, and/or my bosses have which made me bound by them (at time of employment). Readers have no idea what was in this specific NDA either. Maybe it was all just theater?

Either way how does it help the authors credibility to show that they will wiggle around to avoid signing an NDA? Just tell them you won’t sign an NDA and see what happens.

Pages earlier you mentioned turning off the video but keeping the audio on in the Mashinsky interview. Are you guys trying to do “gotcha” interviews in an industry filled with people (criminals) making cringy music videos?53

On p. 89 they write:

While I agreed that, everything else being equal, employment was a good thing, I couldn’t help but notice the flimsy underpinnings of this otherwise sturdy mining operation. This company was using enormous amounts of electricity to mine speculative digital assets to keep a zero-sum game of chance going. Texas’ notoriously over-worked electric grid, also known as ERCOT, had gone down after a winter storm in February 2021, contributing to the deaths of 246 people. Mining Bitcoin hardly seemed worth the potential harm to the population.

While I agree with much of this statement, I don’t think it is completely fair to connect Bitcoin mining with mismanagement by ERCOT in February 2021. Maybe that argument is stronger in November 2023 but 30 months ago this large facility was not fully operational.

Also, the authors should be clearer: Riot currently only contributes proof-of-work hashing for one specific chain, Bitcoin. Digital assets should probably be singular, not plural, in the next edition.

On p. 90 they write:

What benefit did any of this produce for the rest of us? Was it worth the cost? In 2021, the greenhouse gasses released to produce the energy consumed by Bitcoin and fellow networks more than offset the amount saved by electric vehicles globally.

This is a good point muddied by “fellow networks.” What are the fellow networks? For example, in my February 2021 paper I provided estimates not just for Bitcoin but also for Ethereum (pre-Merge), Litecoin, Bitcoin Cash, Monero, BSV, ZEC, and Dogecoin. Are these what the authors had in mind when they mentioned “fellow networks”?

On p. 90 they write:

It was all ridiculous, but I kept coming back to the same thing. Economically, the parabolic rise and fall of bubbles was well established. But what would crypto’s downfall do to this community?

This is a great question that is never answered. How many jobs does Riot contribute to Rockdale? How many jobs do Bitcoin mining (hashing) operations contribute to across the U.S.? It’s probably negligible but the authors raised these questions and never answered them.

Despite the issues with the nuances of mining, I still think this particular section could be the foundation for a good future chapter focused on proof-of-work mining in the U.S. To date no one outside the coin industry has written a long-form non-hagiographic explanation of how large hashing operators hone in on specific regions due to subsidies and/or acquisition of say, a retired coal power plant that becomes unretired. For instance, how Stronghold Digital Mining bought two languishing coal-fueled generating facilities in Pennsylvania and ramped up their production.

We have seen organized greenwashing from coin lobbyists such as Coin Center but only piecemeal pushback from investigative journalists. For instance, here’s one of the all-time greatest (leaked) RFPs:

Source: Twitter

The second edition has a lot of potential when they dig into what the lobbyists have tried to whitewash and greenwash. Environmentalist Ketan Joshi has documented some of these attempts.

Chapter 6: The Business of Show

This chapter had some interesting potential, to discuss the ‘Brock Chain’ (Brock Pierce)! The authors visited Bitcoin Miami, albeit the 2022 edition and not the arguably more-coke-filled 2021 edition. Alas, while they do discuss El Salvador at the end there is no mention of former Russia Today host, Max Keiser and his wife (Stacy Herbert), who are official advisors to Bukele… and was a bit bananas at Bitcoin Miami 2021.

Anyways, let’s start off with a humblebrag on p. 91:

On April 1, 2022, our months-long investigation into the world’s largest crypto exchange, Binance, was published in the Washington Post.

Their Washington Post article was good albeit a little short, clocking in at around 2800 words. And most of that Washington Post story is reused – word for word – in the first part of chapter 6 (specifically the bits about Francis Kim and Fawaz Ahmed). That’s perfectly fine and common by the way (I myself reused portions of articles and papers in one book). Readers looking for some more depth might be interested in reporting by Tom Wilson from Reuters who was actively investigating the same topics at the same time.

On p. 92 they write:

The second, and perhaps more important, reason crypto took off in China was to avoid capital controls. The official limit of $50,000 in overseas foreign exchange per year is an attempt by the state to restrict wealthy Chinese from moving their money out of the country. If you are a Chinese billionaire, there are numerous ways to get around this, but one of the less expensive ones is crypto. Either buy crypto with yuan and cash out into dollars or other currencies overseas, or perhaps better yet, invest in Bitcoin mines (often using electricity stolen from the grid) and then move the mined Bitcoin via crypto trading elsewhere.

They reference a 2020 article from South China Morning Post, but I think it is a bit of a stretch to make a couple of the specific inferences that McKenzie and Silverman do. For instance, the article does not mention billionaires at all or that Bitcoin mines “often use electricity stolen from the grid.” Maybe both of those are true, but neither are mentioned in the article. Scrolling through my archives, I quickly found one example in Hunan province.

In fact, the article specifically mentions how USDT became popular in China:

Ironically, Beijing’s ban actually fuelled the adoption of Tether in China. Chinese users started replacing the yuan with Tether as the de facto currency in cryptocurrency trades, purchasing it under the table from unregulated “over-the-counter” brokers.

I have no affinity for Tether LTD but that detail wasn’t mentioned in the chapter. Wonder why?

On p. 93 they write:

Binance allows its customers to employ enormous leverage—at one point up to 125-to-1 (now down to 20-to-1 for most customers, comparable to other exchanges). That means retail traders can gamble with far more chips than they actually bought. The upside is large, but so is the downside: At 125-to-1, for every 1 percent move, your one-hundred-dollar bet could net you a fortune, or wipe you out instantaneously. Kim was trading with 30-to-1 leverage. In mainstream financial markets, offering extreme amounts of leverage to retail traders—not accredited investors who must prove they have the funds to withstand a margin call—is not allowed

That is mostly accurate and fair but with one nuance: foreign exchange (FX) trading platforms do offer – and advertise – high leverage, even beyond 125x. For instance, according to Benzinga, at least three FX platforms allow higher than 125x leverage.  Whether cryptocurrencies / assets like bitcoin are the same as FX is a different matter, but Diehl et al., made the same error.

As of this writing, the global FX market is the largest most liquid market in aggregate (and filled with oodles of retail punters).54 This is not a defense of Binance rather it is to highlight how wording and nuance are important. High leverage is allowed in certain “mainstream financial markets.”

On p. 94 they write:

If that weren’t enough, Binance itself trades on its own exchange. In traditional markets, this kind of arrangement would never be allowed, as the conflicts of interest—and potential for market manipulation—are glaring.

This is a good point, and I agree with it. However contrary to the authors conviction, this kind of arrangement has been allowed at various eras in traditional markets: Glass-Steagall (which the authors briefly mention later) separated commercial banking from investment banking in 1933. Fast forward sixty six years later, in 1999, most of it was repealed. Some economists such as Joseph Stiglitz and Paul Krugman opined that this set the stage for the 2007-2008 financial crisis. And guess what, even after the financial crisis and a myriad of debates, Glass-Steagall was still not restored. Yes, even today, too big to fail banks still have these “glaring” conflicts of interest.

On p. 94 they write:

Imagine the New York Stock Exchange or Nasdaq taking positions on different sides of trades it facilitates. No financial regulator would allow it, for obvious reasons.

I agree with the thrust of their argument, even though it is not really accurate.55

What is incorrect? While the NYSE and Nasdaq do not custody user funds and in theory – only provide order matching – the parent companies of both are equity holders of a handful of clearinghouses in the U.S. 56

What would have been helpful in this book (and others post-FTX collapse) would be to describe the similarities and differences in clearing and settlement (C&S).57 These socially useful activities (C&S) are operated by systemically important financial institutions (SIFIs), which in the U.S. are overseen by the Fed Board of Governors. And at an international level, the Financial Stability Board (FSB). Post GFC, post-Dodd Frank we actually have a more concentrated set of SIFIs with conflicts of interest throughout the entire trade life cycle because of how interconnected ownership has become.58 One of the best articles that concisely describes this convoluted relationship is How a Lone Norwegian Trader Shook the World’s Financial System.

Again, I agree with the point the authors are trying to make, but they could have used a better example.

On p. 96 they write:

At one point, according to a screenshot of a chat with a Binance customer service representative that Kim shared, he was offered a voucher for $60,000 in Tether and another $60,000 in trading credits as an inducement to keep him on the very platform that he felt had robbed him.

Perhaps it is just me, but I do think the authors to describe “Tether” as both the unit-of-account and the issuer is confusing. USDT would have sufficed.

On p. 97 they write:

Liti staked $5 million to support the suit, which was being led by international law firm White & Case. Binance’s user agreement requires litigious customers to submit to arbitration at the Hong Kong International Arbitration Centre. With a minimum cost of $50,000 for the services of the court and a qualified arbiter, this clause in the agreement creates a prohibitive barrier for traders who lost a few hundred or thousand dollars seeking restitution. By pooling millionaire day traders with mom-and-pop claimants, and using the backing of Liti Capital, White & Case got around that hurdle.

What is the status update for this? The official website of the Steering Committee for the Binance Claim does not seem to have been updated for a couple of years. The last tweet from the account was September 18, 2021.

On p. 98 they write:

According to their analysis, Binance has become the perfect playground for professional trading firms to clean up against unsophisticated retail traders. Using state-of-the-art algorithmic trading programs and access to the latest market-moving information, these firms are both faster and more powerful than the regular Joes they compete against.

This is probably true, professional high frequent trading (HFT) operations have an edge versus retail in traditional finance so maybe the same odds (or worse?) in the coin world?

On p. 98 they write:

Ranger compared what was happening on crypto exchanges to the online poker craze of the mid-2000s. Back then, you had a sense of the stakes and could see who was beating you at the virtual table. “At least poker’s kind of honest,” said Ranger. “You’re losing to this guy named, like, Penis420, and he bluffed you out of your cash, and you’re here.” But for average crypto investors/gamblers trading on Binance, there was no such clarity. Across the table could sit an advanced computer trading program. Regular traders don’t stand a chance; when the professional firms easily outmaneuver them, they can get wiped out in seconds.

This passage is a little confusing. The poker analogy makes sense in poker but what persona are the authors describing in the last sentence? Day traders? Leveraged traders? How to “regular traders” who buy and hold and do not have leverage get wiped out in seconds? Maybe they gobbled up some junk coins?

On p. 99 they write in parenthesis:

Zhao himself said that Binance may eventually lose out to more nimble and harder-to-regulate DeFi, or decentralized finance, exchanges.

We are nearly a hundred pages in and still no cohesive explanation of what “DeFi” is or what examples of a decentralized exchange is.

On p. 99 they write:

It was hard to see how this “democratization of finance” was going to lead to a fairer economy rather than a more chaotic one, with a vast gulf between winners and losers. The liberatory rhetoric and experimental economics of crypto could be alluring, but they amplified many of the worst qualities of our existing capitalist system while privileging a minority group of early adopters and well-connected insiders.

This is a really good point, I agree with it. The one caveat I would make is that not every intermediary operator claims to be trying to “democratize finance” so a future edition should provide a specific name.

On p. 100 they write:

Surprisingly, the press passes actually came through. We received an official invitation to make a pilgrimage with the true believers.

Why was that a surprise? How many events / venues / interviews rejected press pass requests while writing this book?

On p. 100 they write:

Peter Thiel, the arch-capitalist fifty-four-year-old cofounder of PayPal, was throwing one-hundred-dollar bills from the main stage, trying to signify their unimportance. When members of the crowd rushed to grab them, Thiel appeared shocked. “I thought you guys were supposed to be Bitcoin maximalists!”

Welp, I chuckled at something Thiel said, time to call it a day.

On p. 101 they write:

But first, I wanted some merch. Across the sprawling Miami Beach Convention Center, the product and sales pitches ranged from free NFTs to getting in on the ground floor of the next ICO that seemed a lot like the last ICOs. A DAO promised an investment scheme to “democratize yachting.” Crypto mining machines sold for thousands of dollars each.

This chapter would have been solid if it simply described the crazy claims made by the kiosk participants. One nitpick though: which crypto mining machines sold for thousands of dollars each? Because Bitmain has sold hashing equipment for years that cost roughly that. Is that a lot or a little money?

On p. 101 they write:

If you ignored the formal hysterics and instead talked to regular folks milling about the conference, Bitcoin Miami sometimes felt like just another trade show. Big and energetic, full of boozy salesmen talking about how Bitcoin had changed their lives, with sponsorships adorning every surface, it was a Potemkin village of American consumerism and gambling addiction masquerading, in typically humble crypto fashion, as the future of the entire financial system.

Excellent prose!

On p. 102 they write:

“In Miami we have big balls,” said Francis Suarez, Miami’s Bitcoin bro mayor, who has toyed with the idea of abolishing taxes and funding the city through a nearly worthless token known as MiamiCoin.

The authors missed a golden opportunity to dunk on MiamiCoin, which lost more than 95% of its value in the span of 9 months and Suarez himself lost $2,500 on it.  

On p. 102 they write:

The local faithful, while zealous, were peaceful. No one yelled at me at the Bitcoin Conference or denounced me as a nonbeliever. Some people overflowed with solicitous generosity—there was at least one strip club invitation that I believe wasn’t a covert marketing stunt. The lack of open conflict was almost a letdown—and an indicator of my own latent narcissism, perhaps. Everyone was just excited to talk to some guy from TV that had cameras following him around.

You all should come with me sometime because I’ve had plenty of threats made against myself both online and offline! Someone even called my wife a chink. Classy! Also, why was McKenzie expecting open conflict?

On p. 103 they write:

There are many different ways one could define the crypto community, but the cynic in me would say there were none, not really. The majority of the people in Miami seemed only loosely tied to one another through commerce. They had few other bonds to speak of besides a utopian vision of financial freedom. To me, they were a projection of the timeless American fantasy: getting rich for free as quickly as possible. They flew to Miami to perform the rituals of multi-level marketing-style salesmanship and gladhanding. Also, there were parties.

Excellent writing.

On p. 103 they write:

From his home base in tax-friendly Puerto Rico, Brock maintained numerous crypto business interests and had become one of the industry’s most colorful spokespeople. I hadn’t expected to stumble upon him like that, but Brock—an insider with a sketchy past—was an ideal interview subject.

On the topic of crypto colonialism and Brock Pierce, readers might also be interested in an article five years ago: Making a Crypto Utopia in Puerto Rico. A new paper from Olivier Jutel, “Blockchain financialization, neo-colonialism, and Binance” is also a must-read.

On p. 104 they write:

The goal of interviewing Brock was to talk about Tether, the company he cofounded in 2014. While Brock had no current involvement with the company, we had heard from a source that he had at one point tried to buy back into Tether’s ownership group for the laughably low amount of $50,000. A source had also told us Brock dangled his political connections to the Trump White House in the hopes of getting back into the good graces of Tether executives like CFO Giancarlo Devasini.

Strangely, at least in the subsequent dialogue provided in the book: neither of those rumors were confirmed or denied. Did the authors ask him about buying back into Tether LTD in the video?

On p. 105 they write:

“I talk to more world leaders, probably, than our secretary of state,” he said. “I’m talking to forty-plus governments.” These statements seemed absurd, the kinds of exaggerations told by a particularly imaginative friend in grade school, but I smiled and nodded. It would take a little forbearance to eventually steer the conversation toward Tether.

Isn’t another logical follow-up: what are you talking to these world leaders about? Are these dialogues with other governments set up by Pierce’s team or solicited by the governments themselves?

On p. 105 they write:

“Why hasn’t Tether been audited?” I asked. His response was telling: He simultaneously claimed that they “probably” were working with a major accounting firm while bemoaning that they had tried and failed “hundreds” of times to get an audit. His reasoning was that no firm would touch them because of the lack of “regulatory clarity” around crypto, invoking a common industry complaint. For us crypto skeptics, this didn’t even rise to the level of cliché. There was plenty of clarity. It was just that companies like Tether tended to operate offshore and outside the ambit of American law. Tether’s executives, who never stepped foot in the United States, were reportedly being investigated by the Department of Justice for bank fraud.

I think it is a fair question that should be asked.59 But what did the authors expect Pierce to respond with? He’s no longer an insider, right? And while I mostly agree with the authors commentary, none of us are lawyers so maybe next edition a reference or quote from a lawyer would be better? Oddly, there is nothing in the reference section even though there are probably are a number of U.S. trained lawyers who would say something similar on the record.

Lastly, during his interview with Laura Shin, Zeke Faux provides an answer on the auditing question too, one that McKenzie or Silverman would probably disagree with. Can investigative reporters agree to disagree?

On p. 105 they write:

Given their role as essentially crypto’s unacknowledged central bank, with a few multimillion-dollar settlements already behind them, the company’s behavior potentially violated all manner of security, banking, and financial laws and regulations. Some even argued that by minting a dollar-denominated digital token, Tether was engaged in counterfeiting. As Jacob liked to joke, one sign that Tether was a fraud was that the company had never sued anyone for calling it a fraud. (As Tether’s leadership surely knows, the discovery process goes both ways.)

Maybe all of this is true, and maybe they are finally hammered by a series of law enforcement actions, but the question I ask Tether Truthers (USDTQ) is: why doesn’t the NY AG re-sue Tether LTD/Bitfinex?

Recall that there was a two year monitoring period after the settlement; the authors are alleging that Tether LTD continues to operate in a fraudulent manner during this time. Maybe that company is indeed up to no good. But the onus is on the authors to provide evidence in this book, and they don’t.

Matt Levine sorta does. If anyone claims to have direct evidence, shouldn’t the logical question be: have you submitted it to law enforcement and/or informed the CFTC and NY AG of possible violation of settlement terms? What about the fact that there is no major price discrepancy between CEXs that do not allow pegged coin trading versus those that do?

Also, why would Tether LTD sue Spencer Macdonald (Bitfinexed) or myself, for having publicly asked what the reserves were prior the settlement agreements with both the CFTC and NYAG? What would they get from either of us? BitPay never sued me after a couple of analytics-based posts. I don’t think a lack of lawsuits is necessarily a strong argument. 60

On p. 107 they write:

“Of innovation in general. I can’t really share the conversations I’ve had . . . National Security Council and things . . .” I may have involuntarily laughed at that point. Obviously Brock Pierce would not have attended an NSC meeting!

Great line, why would Pierce brag about something that didn’t happen? Bananas.

On p. 107 they write:

Risk-tolerant crypto traders and exchanges owners were stacking leverage on leverage (or fake dollars on top of fake dollars) to extract returns—in real dollars—on their investments.

The bigger story probably was undisclosed / unknown rehypothecation occurring at centralized lenders. But they only touched on Celsius so far. Also, what is a fake dollar? If the authors mean that collateral backing loans wasn’t there then that’s probably true, if so, would that be undisclosed rehypothecation?

Source: Twitter

The tweet above (Barry Silbert is the founder of DCG) did not age well. During the process of writing this review, the NYAG sued Genesis, DCG, and Gemini for allegedly defrauding investors.61

On p. 107 they write:

Tethers were being printed by the billions and issued to a very small group of important players like crypto mogul Justin Sun, who issued a token called TRON, along with sophisticated trading firms like Cumberland and Alameda Research, the Bahamas-based outfit owned by Sam Bankman-Fried, known in the crypto world (and now beyond) as SBF.

Would be helpful to have a diagram explaining the USDT minting / redemption process and who allegedly participates.

For example:

Source: OfNumbers

Above is a rough stab at a flow of funds of user behavior in April 2015. What do those flows look like in 2023?

On p. 107 they write:

Those players then gambled with the Tethers. The supposedly democratizing, decentralizing currency of the future had come full circle: a way to enrich the few at the expense of the many, in opaque games of chance the public couldn’t hope to understand.

This is a strawman. You don’t have to like cryptocurrencies or blockchains but portraying USDT – which is centrally issued – and Tether LTD as “democratizing and decentralized” is disingenuous.

The final few pages of this chapter are great, the authors interviewed two exiled Salvadorans in Miami: Mario Gomez and Carmen Valeria Escobar. Rather than quoting portions here, I do recommend grabbing a copy of the book for those final interactions plus the next chapter.

Overall this chapter had some good gems, such as the interview with Brock Pierce and the Salvadorians. But the authors also made some unforced errors that were a real distraction, such as not knowing that there are existing conflicts of interest within U.S. banks that regulators continue to allow (post Glass-Steagall).

Chapter 7: The World’s Coolest Dictator

This was the best chapter in the book and unfortunately it was also one of its shortest, clocking in at just 12 pages. While it weaves some good prose in with first-hand reporting, the authors still use terms like “coiners” without providing a definition.

Let’s start off with the obligatory reminder that one of the authors was/is a TV star. On p. 113 they write:

He was easy to spot. He held a placard with the alias I use when traveling, Don Drysdale, and wore a Batman T-shirt. Napoleon turned out to be a fan of Gotham, the Batman prequel TV show I starred in that centered on a young police lieutenant (and future commissioner) named Jim Gordon.

Most of the remaining part of the chapter is significantly less cringy and the description of Bukele and how he rose to power is pretty solid.

For instance, on p. 119 they write:

Unfortunately for his people, the young leader refused to accept defeat, instead doubling down on his Bitcoin wager. Bukele changed his Twitter handle to “world’s coolest dictator,” and his profile picture sported laser eyes favored by Bitcoin maximalists, or maxis, who believed that Bitcoin was the one true cryptocurrency and the rest imposters, mere shitcoins. Bukele bragged that he bought Bitcoin, using the state treasury, on his phone while sitting on the toilet.

This is the closest we get to a working definition of a “Bitcoin maximalist,” it is not horrible but does not really encompass the nuances that one the first maximalist extolled.62

Pages 120-122 have some solid interviews with Salvadorians who ended up on the wrong side of Bukele, including a family who lived in a house that unfortunately would be demolished to make way for the new airport for Bitcoin City. What is Bitcoin City and why does it need an airport? Read the book.

One nitpick (timing wise) has to do with one of their comments on the bottom of p. 122:

By the time we visited in May 2022, the issuance of the bond had been delayed, seemingly indefinitely. Despite the ill-conceived scheme, there were still consequences for the local population.

To be fair, if I were in their shoes, I probably would have written the same thing. However following the book’s publication there was a 180% rally in El Salvadorian government bonds. The following month, in August, Bloomberg ran a headline Bitcoin-Touting Bukele’s Bond Rally Draws JPMorgan, Eaton Vance. And as of this writing, the rally has not cooled off.

On p. 123 they write:

Despite the tense environment, Wilfredo welcomed us to his home with open arms. I immediately noticed what I would come to understand as his signature expression: a broad, easy smile revealing several gold-capped upper teeth. As we fumbled to communicate, first through my poor Spanish and then by way of Nelson translating, he was patient and wry with his replies. Here was a famous Hollywood actor who wanted to film and interview him, to tell his story, yet no one in his own country could tell him when he would be kicked off his land or where he might go.

As mentioned in the beginning of this review, McKenzie’s remark comes across as a little tone deaf. Why not use your notoriety to stop Wilfredo’s home from being demolished? The purpose of the book – according to the Author’s Note – is to condemn those who committed fraud. And what about helping the victims too?

Overall a decent chapter and one that could be expanded in a future edition or even used as a standalone spinoff.

Chapter 8: Rats in a Sack

This is one of the weaker chapters because it relies almost entirely on repeating news from other sources. And unlike the previous chapter, nothing really knew is revealed that we couldn’t learn from other books or mainstream news sources.

There is also an introduction to some important concepts that once again, are not explained.

For instance on p. 128 they write:

The two were bound together via an arbitrage system designed to keep Terra, a so-called algorithmic stablecoin, at one dollar.

What is an algorithmic stablecoin? Are all algorithmic stablecoins the same are are there differences?

On p. 128 they write:

Or so went the plan. There was also a “staking pool” called Anchor, which was also created by Do Kwon and his company, Terraform Labs.

What is a staking pool? Is that the same thing as a validating pool used by some proof-of-stake networks? Or are there differences, like a whitelist maintained by a 3rd party?

On p. 128 they write:

Sure, there was the occasional bit of criticism. The economics of Terra, Luna, and Anchor were clearly Ponzi-like, involving the circular flow of money common to such schemes. Where was the 20 percent return on Anchor coming from?

Strangely, with so much written on Anchor from other sources, they never answer their own question. The short answer is the 19.5% – 20% yield marketed for Anchor was an unsustainable subsidy based on a combination of ANC (the governance token for Anchor) and bLUNA staking yield. Here’s my long form explanation of what happened to Terra last year: Not all algorithmic stabilization mechanisms are the same.

On p. 129 they write:

That the whole thing smelled like a Ponzi was no secret, but rather a fact discussed by some big industry names on Twitter, podcasts, and in other media.

Probably the most prominent Terra critic during that time was a trader, Kevin Zhou, who publicly described the fundamental issues of UST (and ANC) with just about anyone willing to listen. A second edition should include him or at least refer to his interviews.

On p. 129 they write:

But on Mirror, people weren’t trading real stocks in a regulated market. They were trading synthetic copies of real stocks on a market overseen by, well, Do Kwon.

Even the SEC lawsuit does not use this as an argument, because it is not true. Mirror was many things but it was not “overseen by Do Kwon.”

On p. 129 they write:

Can you imagine the gall it takes to set up a fake copy of the New York Stock Exchange, one that, given its shaky underpinnings and nonexistent oversight, might attract who knows what kind of shady players? And then to refuse to even account for it?

Again, this is not the argument the SEC made when it (1) subpoenaed Terraform Labs and Do Kwon and (2) sued them.

This is important because it hurts the credibility of the authors: right now there are more than a dozen stock exchanges operating in the U.S. These stock exchanges are not all the same, some offer traders different functions and different products. Some purposefully attempt to mitigate the advantages of HFTs. Some process significantly more volume than others.

But a key similarity is that say for equities, a share of Apple stock, none of these exchanges has a monopoly as the trading venue for that stock.

In contrast, some exchanges, like the commodities-focused ones, have a monopoly on specific futures contracts: you can only trade it on one exchange. For example, the WTI Crude futures contract that is frequently quoted in financial press is only tradable at the New York Mercantile Exchange (NYMEX).

The SEC sued Terraform Labs for selling unregistered securities. Not for making a new trading venue.

And in June 2022, a U.S. court rejected Do Kwon’s appeal:

The court stated that business arrangements with U.S. companies to trade assets from the Mirror Protocol justified the SEC’s investigation, where “a $200,000 deal with one U.S.-based trading platform” was made. Furthermore, the Terraform Labs “indicated that 15% of users of its Mirror Protocol are within the U.S.” during negotiations.

It’s unclear why the authors thought the appropriate analogy was a “fake copy of the New York Stock Exchange” when that type of example does not appear in the complaint. 63

On p. 130 they write:

Almost a year later, one LUNC was worth about one thousandth of a cent, but the token’s overall market cap was still in the top fifty of all crypto tokens. That signaled two things: Crypto was dominated by what were essentially penny stocks, and even in a disaster like TerraLuna, a lot of people hadn’t given up hope. They were holding on.

To be fair to the coin world: penny stocks originated the pejorative, penny stocks. Maybe the next edition can use “Lunatics” as a coin-specific pejorative?

On p. 132 they write:

In the midst of all this, Terraform Labs’ entire legal team quit at once.

The authors missed the opportunity to find specific tweets to dunk on, such as one lawyer who mentioned how they lost everything including their significant-other… just weeks after bragging about how wealthy they now were.

On p. 132 they write about the cascading collapse of centralized lenders in the wake of Three Arrows Capital (3AC) insolvency:

Blockchain.com, a crypto exchange, was due $270 million. The contagion had spread.

The authors were pretty miserly when it came to graphics and images, one they should include in the next edition is this whammy:

Source: Twitter

It is a self-attestation from Kylie Davies, co-founder of 3AC to Blockchain.com. This was basically all the due diligence the lender did. Check out my March presentation for more doozies.

On p. 134 they write:

After devouring tech talent the previous year, big exchanges like Crypto.com (usurpers of the naming rights to Staples Center) and the Winklevoss twins’ Gemini conducted multiple rounds of layoffs, sometimes without any public announcement, in just a few months.

Usurpers? They are naming rights not a birth right and Staples had a 20 year deal beginning in 1999. What should the stadium be called?

On p. 134 they write:

One of them was BlockFi, another crypto lender that offered huge, and unsustainable, interest rates on customer deposits.

Pretty easy to say after the collapse of the bubble. For what it is worth, I publicly questioned BlockFi’s yield in 2019 and got lampooned by Andrew Kang, Nic Carter and Rob Paone.

Source: Twitter

Deep analysis!

Spongebobbed!

What were the books authors doing in March 2019?

It is all too easy to come after the bubble and publish a mostly second hand account about “huge and unsustainable interest rates” after the lender filed for bankruptcy, the harder part was publicly discussing where the yield comes from prior to the bubble.

Source: Bloomberg

On p. 134 they write:

The curtain was being slowly peeled back through a steady diet of leaks, bankruptcy filings, and the first wave of lawsuits. Important revelations were emerging, some of which confirmed earlier criticisms from skeptics.

What specific criticism? Which “skeptics”? Please provide the receipts.

On p. 135 they write:

The entire crypto economy depended on Tether’s stablecoin—it was by far the most traded token each day. But its murky operations, uncertain financial backing, and bloviating executives—to say nothing of those executives, like CEO Jean-Louis van der Velde, who were almost never heard from—didn’t seem like the makings of an organization that could weather a major industry downturn. At some point, I believed, the bill would come due for Tether, and it would be one it couldn’t afford to pay.

The first sentence is probably true for some (most?) spot exchanges, but not necessarily for on-chain trading.

For instance:

Source: The Block

The color-coded bar chart (above) visualizes the different on-chain volumes of USD-denominated pegged coins. While USDT-based volume is large, USDC is often much larger. Strangely the book doesn’t discuss other centrally issued pegged coins at all.

On p. 137 they write:

And all the while, scams, rug-pulls, hacks, and Potemkin crypto projects proliferated, adding billions more to the toll that comes with being part of the web3 community.

Since “web3” is never formally defined in the book, this dunk doesn’t really bite. Are readers supposed to assume anything blockchain-related suffered from billion dollar scams and hacks during this time frame? Or did the damage primarily impact intermediaries? Where’s the shade for Certik?

On p. 137 they write:

Perhaps the most disturbing part of the crypto crash of the spring of 2022, which wiped out more than $2 trillion in notional value and wrecked the nest eggs of everyday traders all over the world, was the utter lack of humility shown by the industry’s leading figures. Materially, most of them were fine: Their predictions might have been ludicrous, and perhaps they lost oodles of money—but it was usually someone else’s money, and they had made enough insider profits along the way to simply hop over to the next project, should the current one fail. Many had also bought in early to Bitcoin, which still held some value, even if it was 60 percent or more below its peak.

There is a lot to unpack here. I agree with the authors, that a lot of the shills and prominent promoters lacked humility. Coinesia writ large.

But the authors are playing fast and lose with the word “most.” How many were fine? How many bought bitcoin early? How many had made “enough insider profits”? I’m sure some coinfluencers check all of those boxes, but readers are never given even a ballpark estimate.

On p. 138 they write:

As trillions of dollars of wealth evaporated

If we take “market cap” at face value, the aggregate coin market cap peaked just north of $3 trillion in November 2021 and dropped to around $1 trillion where it currently gyrates. Saying “trillions” seems like an embellishment.

On p. 139 they write:

The truth is that most of the scammers and con men were tolerated—or even encouraged—by the wider crypto industry because there was no economic incentive to do otherwise.

This is a fair point. Though not everyone encouraged or tolerated these bad actors. Some even publicly called them out.

On p. 139 they write:

While I had been shouting to the Twitter rafters trying to warn people of the impending financial disaster I sensed looming, seasoned academics were articulating a more nuanced version of the same.

Buddy, you didn’t start tweeting about any of this until after the bubble peaked in 2021. The time to warn people was in 2018-2019.

On p. 139 they write:

Hilary Allen, professor of law at American University, wrote a paper in February 2022, just three months before the crash, referring to cryptocurrency and its assorted DeFi products as effectively a new form of shadow banking.

Allen’s paper, while sincere in its concerns, made several major errors.64 A number of people, including myself, attempted to explain some nuances that she missed. For instance, she claimed that lending protocols effectively provide unlimited leverage. However, in practice not only do all of the major lending protocols implement a form of whitelisted assets but each of those assets has a loan-to-value cap.

For instance, p. 938 of her paper is factually incorrect in a couple of areas, she did not incorporate the suggestions from experts. That part of the paper should not have passed peer review. Empirically, while many centralized lenders collapsed in 2022, none of her predictions she made came to pass specifically regarding DeFi lending protocols. 65

On p. 139 they write:

Broadly speaking, shadow banking refers to a company offering banking services while avoiding banking regulations.

The authors are finally discussing what a shadow bank is. If you recall, in the first chapter they mention PayPal but fail to mention it was one of the first prominent fintech “shadowbanks.” A number of centrally-issued pegged coins issuers (like Tether LTD) have modeled their operations after the path pioneered by PayPal, as a shadow payment and shadow bank provider. None of that is mentioned by the authors (or Allen).

On p. 140 they write:

We know this happened during subprime, but as Professor Allen points out, the leverage in crypto, especially DeFi, is far higher. “The amount of leverage in the system can also be increased by simply multiplying the number of assets available to borrow against,” she writes. “That is a significant concern with DeFi, where financial assets in the form of tokens can be created out of thin air by anyone with computer programming knowledge, then used as collateral for loans that can then be used to acquire yet more assets.”

Allen and the authors are not only incorrect but they do not even provide a number, what is the leverage? That which is asserted without evidence can be dismissed without evidence.

Specifically the part where Allen is wrong is claiming that any amount of tokens can be created out of thin air and used as collateral for loans.66 In practice, only about thirty different coins and tokens have been whitelisted on DeFi lending protocols such as Aave or Compound.

Fun fact: the authors never mention specific lending protocols in the entire book.

On p. 140 they write:

The people behind crypto coins can create endless amounts of fake money. Crucially, the exchanges themselves can also do so, in the case of coins like FTT (FTX) and BNB (Binance). If folks can use that fake money to borrow real money, that’s a problem, as the leverage is potentially unlimited.

This is absurd.

If the authors were right, then none of the centralized lenders would have gone bankrupt last year because they would have just created endless amounts of fake money and continue to lever up and up. They could not because there is no such thing as unlimited leverage in either DeFi or centralized lending.

Why make this up? There was real provable criminal activity taking place, why resort to exaggerating like this?

This again reminds me of another evergreen tweet from Matthew Green:

Source: Tweet

On p. 142 they write:

Crashes happen in regulated markets, but at least there is some flexibility built into the system—whether it be negotiations between the parties, court cases, or even government bailout—that can mitigate the damage. At the end of the day, licensed banks in the United States are backstopped by a trusted third party, the US government. Cryptos are famously trustless, so no such third party exists. Not only that, but rigidity lies at the very foundation of crypto itself in the form of so-called smart contracts.

This is a pretty shallow explanation of how the U.S. financial industry is overseen and regulated by different state and federal regulatory bodies. Sure due to time and space constraints the authors need to be brief, but there is no delineation between state-chartered and nationally chartered banks. Or the role that the FDIC or OCC play. Or how in times of crisis the Federal Reserve acts as the lender-of-last resort. Or what role international bodies, such as the Financial Stability Board, play “at the end of the day.”

Also cryptos, which by now is the catch-all term the authors use to capture all cryptocurrencies / cryptoassets, are only “trustless” in the on-chain realm (assuming the chain is actually decentralized). Most of the criticism in this book, so far, seems to be around activities of off-chain intermediaries such as centralized lenders.

On p. 142 they write:

Smart contracts are basically small computer programs designed to execute their functions immediately, without the interference of a financial intermediary, a regulator, a court, or the parties themselves. The irreversibility of the blockchain—it’s an immutable ledger that can only be added to, never subtracted from—and the smart contracts built around it means DeFi is far more rigid than TradFi. Most actions, once performed, cannot be undone. When an interconnected system falls apart, this is not a good thing.

I wrote an entire (outdated!) book in March 2014 on this topic and the definition above is superficial at best. For instance, smart contracts do not have to execute all of their functions immediately. On permissioned chains – or even permissionless chains – intermediaries can even play a role. In fact, that’s precisely what real world asset (RWA) issuers due via black listing and white listing of addresses such as Aave Arc.

When the authors say “DeFi is far more rigid than TradFi” that could be true but they do not follow-up with any evidence. That which is asserted without evidence can be dismissed without evidence.

For instance, you would think an easy slam dunk example they could provide is the fallout from The DAO hack in 2016, such as a hard fork. But that famous hack is not mentioned anywhere in the book. Are the authors aware of what happened? If so, surely that would be a good way to steelman their view in the next edition.

On p. 142 they write:

Complexity leads to fragility. The more complicated the financial mousetrap you build, the more likely it is to fail.

What evidence or source do they cite to back up these claims? Nothing. They are just opinions. That which is asserted without evidence can be dismissed without evidence.

On p. 142 they write:

Blockchain, consensus algorithms, smart contracts, and cryptographic signatures are all real human creations whose value we can debate. As individual components, they may all have positive attributes, but combining them together in a more or less unregulated marketplace has become self-evidently problematic. Unless, of course, you were just trying to use that complexity as a smokescreen to commit fraud.

If a large commercial bank, such as J.P. Morgan were to start using smart contracts for a blockchain-based project, does that a priori mean that JPM is “using that complexity as a smokescreen to commit fraud”? That is how weak the authors arguments have become in this book.

Onyx may fail, but it serves as a counterfactual to the a priori arguments used by the authors. Launched in 2020, this blockchain-based project from J.P. Morgan exists. Is the bank using it to commit fraud? Who knows, maybe the authors could weigh in.

On p. 143 they write:

Remember my initial thesis: When a bubble pops, the most speculative things fall fastest. Since crypto was entirely speculative, the investment equivalent of gambling, it was bound to go poof when the Fed started raising interest rates.

Perhaps he tweeted it but it is unclear when McKenzie publicly stated this thesis. I actually partially agree with it. But without receipts, he can’t really do a victory lap.

On p. 143 they write:

On March 17, 2022, seeking to counteract inflation, the Fed raised interest rates by a quarter point (or 25 basis points if you want to sound fancy). On May 5, they raised half a point and the carnage began. On May 8, crypto had a nominal market cap of $1.8 trillion. By June 18, it was $800 billion. A trillion dollars evaporated in less than six weeks. The joke was the lie that it had ever been there in the first place.

The whiplash is strong here. Just 13 pages earlier the authors chronicled the collapse of Terra which led to a cascading collapse of centralized trading entities (like 3AC) and lenders (such as Celsius). No one, including the authors, have connected the collapse of Terra with the rise in interest rates. This is a spurious correlation.

Now I would agree with part of the authors arguments that in November 2023, with rates at 5.25%, it is likely that “risk free” investments (such as U.S. Treasuries) are attracting some speculative funds that would otherwise go into riskier assets like cryptocurrencies. But the implosion of Terra – and the subsequent unwind and cascading domino effect onto centralized lenders was mostly self-imposed due to poor risk management (e.g., rampant rehypothecation). In other words: Jay Powell and the Board didn’t pop the bubble, the Board just has stymied that spate of exuberance for now.

On p. 144 they write:

Democratic politicians were taking huge donations from the crypto industry—most notably, from Sam Bankman-Fried—and spending far too much time with industry lobbyists. (We saw the photos on Twitter before you deleted them, guys.)

This is one of just a small handful of times the authors mention coin lobbyists which is a little strange considering how much air cover the coin lobbying industry provides.

Not only did the authors not name names, they did not even reference the Tweet or the date, here it is:

Source: Twitter

Mark Wetjen never registered as a lobbyist for FTX which he is required by law to do (see the Lobbying Disclosure Act). This is considered a big no-no. Wetjen was also on the advisory board of Coin Center as of ~3 years ago (unclear when the lobbying org changed it). Following the collapse of FTX, Pham deleted the picture and Wetjen deleted his Twitter account.

On p. 144 they write:

But crypto, in practice, was nearly always the opposite of what it claimed to be, so of course it ended up becoming a tool for political influence. And because crypto was foremost a way to get rich, crypto investors celebrated the billionaires, like SBF, who were showering politicians with donations in order to legitimize crypto and shape its regulatory future.

This is a great point.

On p. 144 they write:

The previous fall, Bitfinex’ed told us the crypto industry was vanishingly small, controlled by only a handful of players. At the time it seemed far-fetched, but the more bankruptcy filings forced the opaque sector into the light, the more he was proven right.

Unless Macdonald named names, this is just a he-said-she-said. For instance, on October 16, 2021 Macdonald DM’ed me that “Even disclosure of reserves can be catastrophic” and nine days later that “Get ready to buy me that scotch don’t worry I’ll share.”

I have no affinity for Tether LTD or Bitfinex but Macdonald’s predictions above were wrong. And he didn’t even buy me the scotch he wagered.

A couple of times he was, that’s why I stayed in touch with him. But he ended up blocking me for holding him to the same standard we all hold promoters: verify don’t trust. Maybe Tether LTD’s attestations are bogus, maybe they operate in the same fraudulent manner as they did in 2016-2018, but the onus is on Macdonald and others to provide that evidence. And right now, none of the “disclosure of reserves” has been catastrophic.

On p. 145 they write:

Crypto critics and good governance advocates worried about Bankman-Fried’s growing political influence.

Specific examples before 2022? Such as?

On p. 146 they write:

“Help you avoid things that won’t age as well.” It wasn’t the first time a powerful person had tried to shape our reporting, but few were higher on the food chain than SBF. As in all relationships like this, the important thing was to not succumb to that influence, however it might be exerted. As a newly minted journalist, I had begun to realize that competing agendas were all around me, that sometimes we had to mingle with some unsavory people in order to find the truth while still keeping our ethics intact.

This is hard to buy because one of the things readers (at least U.S.-based readers) are aware of is Hollywood entertainers are represented by an agent(s) and have connections with PR firms whose goal is to help promote the entertainer in a flattering light in order to land the next big gig. Competing opinions and agendas are all around Tinseltown, they make movies about it.

On p. 146 they write:

At the same time, I realized something: If these crypto bros were really as cocky as they appeared to be, maybe stirring some shit up on Crypto Twitter would yield results. To use a poker analogy, why not splash the pot a bit, piss some people off? On May 14, I fired off a tweet egging them on: “Anyone in the crypto industry wants to come at me, feel free. Fwiw, I have spent 20 years in showbiz, I can take a punch. Just a couple words of advice: don’t miss.”

It’s nearly impossible to McKenzie seriously since he openly admits to shitposting on social media to trawl for engagement. That is what Instagram influencers do for more attention, not a serious investigative reporter. Zeke Faux didn’t, that’s your peer.

All in all this was one of the worst chapters in the book primarily because it relies on and amplifies Hilary Allen’s false predictions. And also because the authors continue to make a priori arguments instead of evidence-based ones.

Chapter 9: The Emperor is Butt-ass Naked

Despite the adolescent chapter title, the chapter is one of the better ones. Unlike most chapters, this one involved some first-hand reporting on FTX and Sam Bankman-Fried. For readers unfamiliar with SBF, the chapter does a decent job of painting the scene. But for those already steeped in the lore surrounding SBF, nothing new is really revealed.

But there were still a number of unforced errors made by the authors who used unnuanced language.

For instance, on p. 151 they write:

Hong Kong benefited from being close to mainland China, where cryptocurrency had exploded in popularity, due in no small part to the desire of wealthy Chinese to avoid state capital controls.

This may be true, but what is the reference or citation for this? Nothing in the back of the book. If the authors are relying on the South China Morning Post article from earlier, recall it did not specifically mention wealthy people (millionaires or billionaires). Again, anecdotally I think it could be true, but the burden of proof rests with the authors.

On p. 152 they write:

The first was potential conflicts of interest. Sam owned an exchange and a trading firm that operated on that exchange. Imagine if J.P. Morgan owned an unregulated version of the Nasdaq. What was stopping him from manipulating the value of assets on his exchange via Alameda and pocketing the proceeds?

I agree with the thrust of what the authors are saying, but it is not a particularly good example. Recall earlier the discussion around revoking Glass-Steagall. Today J.P. Morgan operates the largest commercial bank in the U.S. which is fused with an investment bank.67

In 2015, J.P. Morgan paid a combined $307 million fine to settle cases with the SEC and CFTC, admitting wrongdoing in part because certain banking units failed to tell clients it favored in-house funds, clear conflicts of interest. In 2020, J.P. Morgan paid $920 million to settle DOJ, SEC and CFTC charges of illegal market manipulation or “spoofing” in the precious metals and Treasury markets.

If the authors were looking for a large unblemished regulated financial institution, there probably is none. So the next edition could just describe why these “conflicts of interest” are abused by CEX operators.

On p. 152 they write:

The second was his company’s deep ties to Tether. In November 2021, Protos, a crypto media company renowned for its skepticism, revealed that Alameda Research was one of the largest (perhaps even the largest) customers of Tether.

Strangely there is no link or reference to the Protos article. Also Protos is sometimes hit-and-miss. While I have found myself nodding in agreement with a couple of their op-eds, they also have a notable few duds.

(1) This past summer they published a byline-free xenophobic article: Uncovering Ethereum’s close ties to Chinese money.68 One of the shadowy reasons is because Vitalik Buterin’s interest in speaking Chinese! Since I worked in China for five years and my wife is Chinese just waiting for a xenophobic hitpiece to drop.

(2) A year ago, Protos published the “Tether Papers” which they billed as being as important – and revealing – as the Paradise Papers. Upon closer inspection it was a dud because the authors – some of the same people that McKenzie and Silverman put on a pedestal in this book – did not reveal anything about market makers you couldn’t already get from a subscription of The Block Pro or Messari or The Tie Terminal. In other words, the investigation was standard market research wrapped in a cloak-and-dagger marketing foil.

On p. 152 they write:

The notoriously shady stablecoin company had printed $36.7 billion for Alameda. We’re supposed to believe Alameda gave over $36 billion to buy thirty-six billion Tether? Where would Alameda have gotten $36 billion from? According to public reporting, they had raised a few billion from VC firms and others, but nothing like what Protos found. If Alameda didn’t give Tether the full amount up front, how did the arrangement work?

These are good questions, none of which are answered anywhere.69 The next edition should explore how this arrangement worked.

The line chart (above) visualizes Alameda’s balance on FTX for the duration of 2022.70 It is negative for all but one day. A second edition should include these types of charts to help readers understand the magnitude of loses.

On p. 152 they write:

The ties between Tether and FTX/Alameda went even deeper. Daniel Friedberg was the former general counsel of FTX, and now its chief regulatory officer. He once worked alongside Stuart Hoegner, the general counsel of Tether, at Excapsa. Recall that Excapsa was the holding company of Ultimate Bet, the online poker site that had a secret “god mode” where insiders could see other players’ cards. So FTX/Alameda’s top lawyer worked with Tether’s top lawyer at the parent company of the card cheating website. Huh.

This is guilt by association and is lazy. I have no affinity for Stuart Hoegner, have even publicly stated so. I’m not going to carry water for Friedberg, but it is disingenuous to slam him without at least referencing his side of the drama.

On p. 152 they write:

Sam posed for a picture with CFTC Commissioner Caroline Pham and was a regular at CFTC offices.

What is the context for that photo? The authors do not provide a reference or link. Scroll up to page 144.

On p. 153 they write:

But banks in the Caribbean were often more willing to engage. And whether coincidentally or not, Tether’s bank happened to be nearby. Deltec Bank, the one run by the cocreator of the Inspector Gadget cartoon series Jean Chalopin, was based in Nassau. Chalopin boasted of assisting the Bahamian government in drafting the DARE Act.

This is an interesting point. I had not heard the part about Chalopin boasting before. Is there a reference or a citation I can learn more about this? Not in the back section unfortunately.

Also, when the authors say “banks in the Caribbean were often more willing to engage” how much easier is it to open an account in an Caribbean bank? Are there some stats to quanitfy this engagement level?

On p. 154 they write:

Still, I was glad he was there, as we quickly realized the room I had rented was too small to fit much more than the five of us in addition to the two cameras. But that also gave me an idea.

It’s never really addressed in the book but: why did the authors need to video tape every interview? There is no separate web page for Easy Money where readers are directed to for additional content, like video interviews. In fact, to the chagrin of SEO, there are at least two films with the same name (released in 1983 and 2010). Did the authors think it adds more weight or seriousness to the F2F interview? Also, as mentioned earlier, last year Alex Gladstein asked the authors to release the video interview of SBF, which they declined.

On p. 156 they write:

I pointed out that Sam himself had publicly stated that most cryptos were in fact securities. He tried to duck it, saying he hadn’t done a “thorough review of tokens 10,000 to 20,000.” This was a common talking point from crypto evangelists; they all knew (or should have known) the bottom 10,000 coins were the functional equivalent of penny stocks, with ownership of the coins heavily concentrated in the hands of a few whales who could manipulate the market for them. Nonetheless, Sam conceded that “the majority are maybe securities by count.”

Pigs flew past my window: I actually agree with SBF on his point. In the U.S., prosecutors conduct an investigation based on the facts-and-circumstances of a coin or token. At a minimum the authors should include a citation or quote from a U.S.-trained securities attorney, which SBF is not. It is unclear why the authors do not cite any attorney in this chapter when there are more than a handful of U.S. trained and practicing attorneys who likely agree with the authors position on the matter.

On p. 157 they write:

Sam pointed out that Bitcoin can only process 5–7 transactions per second. By his own admission, Bitcoin was “four orders of magnitude” away from accomplishing this. It was never going to happen. Finally we agreed on something! But then Sam pivoted. He argued that other blockchains were faster.

Why set up a strawman for the readers? This is not a secret. Historically it was Mike Hearn, the Bitcoin Core developer, who initially came up with that calculation. Subsequently, Hearn wanted to conduct a hard fork to increase the Bitcoin block size so that there could be more transaction throughput. Disagreement with other developers led to the famous blocksize “civil war” in 2015-2017.

And twice in two pages: SBF is right, there are other blockchains on this planet, some that are significantly faster than Bitcoin.

On p. 159 they write:

The Solana blockchain suffered numerous outages since its launch in 2020, with fourteen in 2022 alone. It also had an unfortunate tendency to be hacked, including a hack that would occur just weeks after our interview that cost users at least $5 million.

This is untrue. While there have been outages, as of this writing, the Solana blockchain itself has never been hacked. Since they did not provide a citation, a quick googling found that several thousand wallets were indeed compromised. But conflating wallets with the blockchain hurts their credibility.

On p. 159 they write:

I asked Sam what percentage of crypto was being used for payments. He agreed the “majority of people today are not using it as a payment method” but instead as a “financial asset.” He guessed “$4 billion” of crypto was being used as payments. Crypto’s market cap was roughly $1 trillion on July 20, 2022. Four billion would represent 0.4 percent of that number. Seemed pretty insignificant to me, but then again, could you even trust that Sam’s number—or the market cap number—was real? That gave me an idea.

That estimate could be correct. But of all the things to drill into with the SBF, why burn any oil on this? Central banks and universities researchers regularly publish surveys on the motivations of coin ownership.

For instance, in the process of writing this review:

Source: Twitter

But Tim, this survey was published after the book was done. Yes, but there are similar surveys published each year by different central banks, this wasn’t the first.71

Or more to the point, if the authors wanted to improve their argument, at a minimum they should have sliced some data: asked some analytics providers for flows into payment providers.

For example, in January 2015 I published a paper that included this line chart (below):

Source: Slicing Data

The dataset above came from the WalletExplorer dataset. Because BitPay reuses addresses, it is a visual of what BitPay has received over a two year time frame (2013-2015). It clearly shows that at the time, retail activity was not seeing huge growth that certain promoters claimed.

On p. 160 they write:

Sam expressed cautious optimism that eventually customers in Celsius and Voyager would get some of their money back. I was skeptical but I wasn’t there to argue bankruptcy law.

Fair point, but why argue about securities laws when he isn’t a lawyer either?

On p. 160 they write:

Eventually, Sam got back to the original question. He estimated that there were $100 billion of stablecoins left and that they were “roughly backed” 1:1. (No, I don’t know what “roughly backed” means either.)

Since he is actively responding to your DMs, why didn’t you ask him a follow-up question later?

On p. 161 they write:

“You could say the same of stocks,” Sam said. I pointed out I can go in and out of stocks in seconds via an app on my phone.

This is not particularly good argument because it implies to readers that McKenzie is talking about market orders, which over the past decade are not necessarily good for retail on any type of trading platform. This connects with payment-for-order-flow (PFOF), a controversial business practice implemented by Robinhood (and other fintechs) with its high-frequency trading partners such as Citadel. Robinhood earns the majority of its revenue from PFOF which isn’t necessarily good for the users. Is this the app that McKenzie is referring to?

On p. 161 they write:

We moved on to stablecoins. SEC Chair Gary Gensler called stablecoins the “poker chips at the casino,” I said. Tether was the biggest stablecoin in terms of trading volume by a country mile. “Your company Alameda is one of Tether’s biggest clients.” “Alameda does create and redeem Tether. We’re one of the larger ones doing so.”“Okay, so there was an article from Protos, the crypto publication, from last year that said that Alameda and Cumberland, another trading firm, received $60 billion of USDT (Tether) over the time period they analyzed, which is equal to 55 percent of all outbound volume ever.” “Yep.” “Does that sound right to you?” “Sounds ballpark correct.”

The insinuations and innuendo are getting a bit long in the tooth at this point. The authors should either introduce the “smoking gun” or try a different angle. Because even in the current SBF court case (jury just convicted as of this writing), Tether LTD does not seem to play a major role in the collapse of FTX.

Maybe Tether (USDT) is a key enabler and systemically important infrastructure, I would agree with that. I think there is sufficient on-chain data to show it is a key lubricant to trading in several ecosystems (via Mastercoin, ERC-20, and TRC-20). But readers are not even presented charts or stats that illustrate these points.

On p. 167 they write:

Most people who had ever purchased crypto entered the market in 2020 and 2021, and most of those people had lost money. Sam argued that the people who invested before then had made money, which didn’t refute my point.

This could be true but the authors do not provide any reference or citation. That which is asserted without evidence can be dismissed without evidence.

On p. 168 they write:

Sure, a minority of people who got in early did well. He tried to pivot away from a discussion of price and toward an “ultimate use case.” I was fine with that. One of my biggest problems with crypto was that it didn’t actually do anything anything productive. To that end, I repeated my ask from earlier: Give me one use case for crypto.

Anyone asked this question by the authors should be aware the authors are a priori anti-blockchain. Throughout this book they repeatedly use the same evidence-free approach that Diehl et al., used. McKenzie literally states his view in the paragraph.

So it is hard to have a good faith discussion when they do not seem to recognize the existence of RWAs.72 Also, SBF should have had a better answer considering all of the pitches he had heard.

On p. 169 they write:

In a roundabout way, Sam had gotten to the heart of the matter. While getting a wire transfer can be a major pain in the ass, and I agreed we could improve our payments system and our broader financial system, one of the reasons a wire transfer is cumbersome is that it runs through our banking system, which has safeguards in place: anti–money laundering laws, know-your-customer laws, the ability to protect against fraud. These regulations exist for a reason. We can and should argue over how to improve our system and amend those regulations when necessary, but claiming crypto was better simply because it was “cleaner” and moved faster was either disingenuous or deeply ignorant. Sure, it moved fast, but at enormous cost. Crypto opened the door to facilitating all sorts of criminal activity, and “trusting the code” often meant having to live with hacks, scams, and fraud as a cost of doing business. Plus, the irreversibility of the blockchain meant you couldn’t correct an honest mistake. You lose money? DYOR, man.

This strawman is similar to the type found in Diehl et. al., book. Not every cryptocurrency or blockchain project is attempting to create a bank, or a payment system, or “money.” The next edition needs to be more specific about which projects the authors are referring to here. Or what existing infrastructure they are comparing the strawman with.

For instance, how does McKenzie propose “we could improve our payments system”? Does a wire transfer take three days to move because of KYC and AML processes? FedNow flipped on a couple of months ago, it introduced another real-time payments (RTP) system in the U.S.

Does FedNow cut through the 3-day wire by removing or ignoring regulations? No. The poorly named “The Clearing House”, which operates the other RTP, must be super fast because it bypasses these KYC and AML processes, right?73 No.

The authors inexplicably defend the status quo – including slow incumbent intermediaries – without explaining why it takes a specific unit of time for funds to transfer. Saying that “crypto moved fast but opened the door to all sorts of criminal activity” is sensationalistic writing and not serious investigative reporting.

On p. 170 they write:

I was searching for some semblance of heartfelt contrition on his part, some gesture of sympathy toward the naive crypto-buying masses, but mostly I came up empty. Sam reiterated a generic need for federal oversight. I expressed a hope that, at a minimum, we skeptics could find common ground with industry players like him and work toward eliminating the myriad scams and pervasive fraud in crypto. Sam nodded, his head hanging low.

What are skeptics? Does McKenzie speak on their behalf? Is there a card membership form?

On p. 171 they write:

We said our perfunctory thank-yous. But Sam kept talking. “And always if you guys have any thoughts or questions about the ecosystem. Feel free. And Tether, there’s a lot more I could say off-the-record.” (Off-the-record is by mutual agreement; we never agreed to it.) “Frankly, they’re emotional guys. And I don’t want to piss them off. Weird fucking dudes. Like really fucking weird. They’re honestly not scammers, but they are difficult people. And I think the FT article on Giancarlo is an amazing article . . .”

This is the third time the authors have shown a lack of compunction towards off-the-record conversations. It all sounds like “gotcha” journalism, not investigative journalism. The ends do not justify the means. Worse for the authors, the hot mic does not reveal anything new.

It also reminds me of that same tweet from Matthew Green:

Source: Tweet

On p. 172 they write:

Jacob asked if USDD, a new stablecoin, could be an eventual replacement for Tether. Recently Alameda had announced a financial partnership with Justin Sun, the entrepreneur behind USDD. Sam responded as if he had never heard of USDD. “USD what?” “USDD.” “Which is DD?” “The new Justin Sun algorithmic stablecoin.” “No, no. I don’t know where on the scale from DAI (another algorithmic stablecoin) to LUNA it is, but I think it might be on the bad end of that spectrum.”

What is an algorithmic stablecoin? Still no definition or description or categories. Also, like most of Justin Sun’s projects, USDD did not take off. For example, a year ago its “marketcap” was about 10% higher than it is today.74 Speaking of which, the paragraphs on Sun were pretty solid, a second edition could mention the SEC lawsuit announced in March 2023.

On p. 176 they write:

But if there was one thing that everyone could agree on, it was that Sam Bankman-Fried had it all figured out. Even among the most die-hard crypto skeptics, it was broadly assumed that Sam was making money hand over fist, and whatever shenanigans he might be up to, he would most likely get away with it.

That’s why the victory laps – by anyone – after the demise of FTX, make no sense. As Faux and these authors pointed out, no one knew besides 4-5 people.75

On p. 177 they write:

For example, “every year there was a 25 percent chance that [Terra] was going to crash to less than 50 percent.” Where did that number come from? Interviewing Sam was like punching against air. If this was the king of crypto, was it a kingdom made of sand?

That’s a good question. The next edition should try to track down the answer.

All-in-all this chapter does not provide any crazy revelations. Based on the questions in the SBF interview, the authors revealed they too had no idea what was happening between Alameda and FTX. For instance, if the authors knew what the inner circle knew, then one of the questions that would have been asked is: is Alameda exempt from liquidations on FTX? Instead it was a lot of innuendo around Tether LTD which as of this writing, does not appear to been a major culprit in the downfall of FTX.

Lastly, based on theirs actions, it appears the authors are willing to not only use the content of a hot mic, but also publish content that the interviewer said was off-the-record. The ends justify the means? In this case, the hot mic didn’t reveal anything interesting, so why include it?

Chapter 10: Who’s In Charge Here?

A future version of this chapter has the potential to be very interesting at it could discuss how the coin lobbying world works. Instead, the current chapter is pretty shallow. While one piece of specific legislation is mentioned, readers are not informed of who’s-who in the coin lobbying world, or what spin doctoring they have achieved.

On p. 179 they write:

But to skeptics, and to people unlucky enough to have invested more than they could afford to, the implosion represented something more severe. Crypto was on life support. A market worth $3 trillion in November of 2021 had been reduced to less than $1 trillion—and even that number seemed aspirational at best. As some bankrupt crypto companies stopped allowing customer withdrawals, it was hard to know how much real money was left to back the fake stuff. When I spoke to him in March, Alex Mashinsky of Celsius had estimated that number at less than 15 percent—and that guy was allegedly running a Ponzi scheme that soon went bankrupt. He might have been exaggerating; it was probably even less.

What is a skeptic? The authors still have not provided a concrete definition. Also, the authors state “it was probably even less.” How much less? They never provide a ball park estimate of what they think the “real money” inside the coin world is.

On p. 179 they write:

Michael Saylor, CEO of MicroStrategy, and the guy who encouraged people to mortgage their houses to buy Bitcoin, resigned his position in August.

Inexplicably the authors missed a key event. Michael Saylor resigned on August 2, 2022. On August 31, the Attorney General for DC announced it was suing Saylor for evading more than $25 million in taxes. Surely readers would find that interesting?76

On p. 180 they write:

What was clear was just how widely the crypto virus had infected the general public. Most Americans who bought into crypto did so in 2020 and 2021, when the market was at its peak, having been lured by promises of mind-boggling profits in the crooked casinos. That same majority, on average, lost money as the price of virtually all of these cryptocurrencies had crashed, most by 70 percent or more from their all-time highs.

They could be right but there are no references or citations in the back. That which is asserted without evidence can be dismissed without evidence.

On p. 181 they write:

How in the world was this massive speculative bubble in an industry rife with fraud—and built upon an incredibly shaky economic foundation—allowed to metastasize to such a degree?

Because in part, actual whistleblowers were ignored? And the prosecutors left the government and joined the counsel for the defense? There is a world worth looking into circa 2017-2019 that the authors missed.

On p. 181 they wrote:

In the midst of all this, crypto lobbying expenditures were at an all-time high, and politicians from both parties were touting pro-industry legislation.

What is an estimate for how much these expenditures were in the U.S.? How much was spent lobbying in other developed countries?

One notable example that comes to mind was an intense effort to lobby specific senators, such as Kyrsten Sinema, during the debate around the Infrastructure Investment and Jobs Act in 2021:

Source: Twitter

A future edition should include specific examples.

On p. 182 they write:

The stateless, peer-to-peer currency that would avoid all intermediaries and democratize and decentralize the future of money now needed to kiss Washington’s ass in the present and throw some of the real stuff around. It was either that, or watch their industry go bye-bye.

This is a strawman, not every public blockchain project is attempting to build “the future of money.” But with the second sentence, I fully agree.

Here are a couple times I lampooned the phenomenon specifically with Bitcoin:

Source: Twitter
Source: Twitter

On p. 182 they write:

Ironically, even Michael Lewis, author of Liar’s Poker and The Big Short, was in thrall with the boy wonder, according to reporter Zeke Faux of Bloomberg.

Oh a trifecta of streams almost crossed! Three books published within four months of one another on the same topic.

On p. 184 they write:

Toomey spun his ownership of Bitcoin and the potential conflict of interest as a source of important “expertise” when deciding on regulatory policy. He argued that Washington needed to offer “respect for consumers” to make their own investment choices, despite the fact that the very lack of disclosures inherent in cryptos not being classified as securities kept investors in the dark as to how they might be getting swindled.

I partly agree with the authors view point here. But – and to be clear I am not a lawyer – I do not think the “lack of disclosures inherent in cryptos” is why some might not be classified as securities. The entire facts-and-circumstances exercise that a U.S. prosecutor conducts involves several prongs that the authors mention a couple of times. Disclosures – or lackthereof – is tangential.

On p. 184 they write:

A representative example was Brian Brooks, who was chief legal officer of exchange Coinbase before he became Acting Comptroller of the Currency, only to leave that governmental position to become the head of Binance’s US division. He lasted all of three months at that job, before resigning due to “differences over strategic direction.”

It is worse than that. Brooks was never confirmed by the Senate, he served as an Acting Comptroller and days before leaving he unilaterally published guidance – which he did not request public comments on – that has since been partially rescinded. His next gig was as the CEO of Bitfury, a notorious mining company whose machines at one point consumed 10% of the electricity in the Republic of Georgia.

On p. 186 they write:

Unfortunately, like the majority of crypto investors, most people of color entered the market near its peak in the bull run of 2020/2021 and were now among the ones left holding the bag.

This could be true but what is their source? There is no reference in the back either. That which is asserted without evidence can be dismissed without evidence.

On p. 186 they write:

Many of these issues were known to them, in some form, even if they hadn’t been publicly acknowledged, much less acted upon.

It could be worth the authors time for them to investigate which non-lobbyists spoke to policy makers and regulators in the 2017-2019 time frame. I know I was not the only one.

On p. 187 they write:

The United States of America is unique in the way it separates its regulation of securities from its regulation of commodities. It’s basically a historical fluke.

Actually if the authors had looked into it, they would have discovered it is nearly all political. There have been multiple attempts to merge the SEC and CFTC, including shortly after the 2008 Financial Crisis. The most recent attempts always hit the same road blocks: powerful lobbying forces from the banking industry and their interlocutors: the members of the House and Senate Banking Committees and the House Agriculture Committee. For instance, in 2012 a bill was introduced in the House to merge the two and in 2017 the Treasury department – then led by Mnuchin – weighed in on a proposed merger.

On p. 190 they write:

For many coiners, it was taken as good news, a way of legitimizing the first cryptocurrency by enshrining it under the existing regulatory regime.

What is a coiner?

On p. 190 they write:

There was no fine or criminal prosecution. CFTC Commissioner Wetjen, in the grand revolving door tradition, later entered the crypto industry. In 2021, FTX US hired Wetjen to be its head of policy and regulatory strategy—the mirror to his former governmental position. To recap, the first derivatives exchange in crypto to be classified as such under American law was later found to have engaged in illegal activity, got off the hook, and then later another exchange hired the regulator who oversaw that decision to help guide their maneuverings on Capitol Hill. You can’t make this stuff up.

In the next edition the authors should include the part mentioned above on page 144 that Wetjen did not register as a lobbyist (like he was supposed to) and was also an advisor to Coin Center, another coin lobbying organization. To be fair, the revolving door crosses both ways: probably worth mentioning that after leaving the CFTC, Wetjen joined the DTCC as head of public policy and later the Miami International Holdings which is a holding company that owns several exchanges.

On p. 190 they write:

But the reality is that Bitcoin’s ownership is actually extraordinarily centralized, concentrated in a tiny group of whales and mining pools. In fact, just two mining pools account for 51 percent of its global hash rate, meaning just two large groups control the majority of new Bitcoin created.

This is not a good argument, as it lacks two things: (1) references and (2) nuance. Without references it can be dismissed out of hand as just another opinion; there are some ways to verify the claims but why should I keep doing their homework for them?

In terms of nuance: while mining pools have become important for proof-of-work chains, it takes two to tango. I agree with the thrust of the point, I have made it myself about GHash voluntarily “self-limiting” in 2014. But unlike GHash (which provided a hosted mining service too), the largest pools do not usually run the hashing equipment, those are typically operated by 3rd parties (such as Riot who the authors visited). Thus, it is not technically sound to say that two mining pools control the majority of the new Bitcoin created, because they need the hashing equipment (that generates the proofs-of-work) in order to build a correct block.

On p. 190 they write:

Whoever Satoshi Nakamoto is, it’s a real person or real people. Once again, code does not fall from the sky. One day we may well find out who started this whole nonsense. If so, break out the popcorn, law nerds.

It’s not clear from the rest of the chapter what the authors are implying. Do they mean Nakamoto would be liable for something and therefore sued or charged by a government? If so, why not just say that?

In fact, while I doubt she agrees with the authors modus operandi, Angela Walch authored a paper that they might want to cite in the next edition: In Code(rs) We Trust: Software Developers as Fiduciaries in Public Blockchains. 77

On p. 190 they write:

One meeting included one of Pham’s former colleagues who had gone over to the crypto industry and now was publicly lobbying her.

Who? Name names next time.

On p. 191 they write:

That’s not to overlook the efforts of SEC Commissioner Hester Peirce, whose enthusiasm for the industry is legendary.

The authors missed the opportunity to use the “subprime mom” and “subprime dad” analogy from Lee Reiners:

Source: Twitter

Curiously, while the authors namecheck Lee Reiners in the Acknowledgments, they misspell his name and worse, they don’t actually cite any of his work. Notably, Reiners was the first person to write a long form discussion on the revolving door as it relates to the coin world. In fact, five years ago he wrote a widely circulated article entitled: The Revolving Door Comes to Cryptocurrency. It is a strange omission, credit where credit is due.

On p. 194 they write:

“There really is no legitimate side to crypto,” said Stark. To him, crypto had simply repackaged the traditional get-rich-quick scheme in a shiny, fraudulent wrapper.

While Stark might be correct, what evidence did he provide? If it is asserted without evidence it can be dismissed without evidence.

On p. 195 they write:

“For me it’s all so obvious,” said Stark. “When you ask anybody, ‘Give me one legitimate use for crypto. Give me one thing you can use crypto for?’ I just don’t see it, and nobody can ever tell me anything.”

Why is Stark the final arbiter for what is and is not a legitimate use for crypto? Who died and made him king? If you have already predetermined there are no legitimate use cases, what can someone tell you?

For instance, in the process of writing this review J.P. Morgan announced its Tokenized Collateral Network. They weren’t the first organization to deploy a new chain with “enterprise” customers.

In any case, the authors need to be more consistent in the next edition: are they a priori handwaving all blockchain-related projects out of hand? Or are they going to conduct market research and lots of interviews to drill into say, 100 dapps (categories) from DeFi Llama? Cannot simultaneously be evidence-based and use an a priori cudgel.

On p. 195 they write:

What I found most refreshing about Stark was his concern for people who got caught up in crypto. “You can blame the victim if you want. But the reality is, it’s really not the victim’s fault. They’re being taken in by really sophisticated hustlers.”

What victims has Stark helped? Which hustlers did he bring to justice?

On p. 195 they write:

It was up to critics like Stark—who had no skin in the game, who didn’t make money off of his crypto criticism—to put forward that argument.

What are critics? Are they the same as skeptics?

How do the authors know Stark hasn’t made any money off of his notoriety? Is that really the litmus test? Are the only people worth talking to those who write long LinkedIn posts? If the authors are willing to entertain the idea that “critics” and “skeptics” come in all shapes and sizes, they’d find that there are a ton of industry folks who are quite openly critical and probably even agree with some of the authors views. There is no reason to be insular or have some kind of purity test on these topics.7879

On p. 197 they write:

In combating a false economic narrative, it is crucial to put forth an alternate true one, to reveal the hucksters and con men for who they really are. But Kardashian and her fellow celebs were, at least for the most part, not those fraudsters. They were just a tool, a megaphone used to spread the lies of crypto more effectively.

I agree with this view, whole heartily. But in the next edition could the authors use more precise language? For instance, Kim Kardashian was sued by the SEC and fined $1.26 million in penalties for failing to disclose she had been paid to advertise EthereumMax (EMAX). It was unlawfully touting, not fraud that she was charged with. This is sloppy polemics just like the Diehl et al., book.

Overall this chapter was a wasted opportunity: the authors could have dug into specific coin lobbying organizations, an idea I encouraged them to do. Instead readers are not informed of who’s-who in the coin lobbying world and are twice referred to a Tweet that is never provided (which Pham deleted but others saved). While we are given an overview of specific piece of legislation, the DCCPA, we aren’t informed that an industry insider – Gabriel Shapiro, a lawyer – leaked a draft that put SBF on damage containment mode and contributed to ending its legislative hopes.

As a consequence, readers are not informed of who’s actually in charge here.

Chapter 11: Unbankrupt Yourself

This is one of the better chapters, largely because it involves a bit of first-hand reporting. We learn about Dr. James Block (aka DirtyBubbleMedia) who used Etherscan to identify suspicious transactions. Yet one oversight was not including Maya Zehavi anywhere in the discussion of Celsius. She is an Israeli-based blockchain-focused entrepreneur who was the first person to publicly sound the alarm on Celsius and Hogeg in particular. She should be interviewed in the next edition.

There is not much to nitpick in this chapter. For instance on p. 206 they write:

At the time, before many industry players turned on one another, there was a collective omertà against bad-mouthing competitors.

Omertà is a great word and I want to agree with the authors here. But tribalism is still quite common irrespective of market conditions, especially the uno coin maximalism variety. Heck, I got yelled at last year for talking about the etymology of “nocoiner” tribalism. Talk about social media wasting your time!

On p. 207 they write:

Soon, James discovered that Chain.com, a murky startup with a lot of crypto but seemingly only one employee, may have been behind it. James and Jacob had been looking into Chain, and James wrote a piece about the CEO’s extravagant purchases of multimillion-dollar NFTs. It turned out that after James published his Dirty Bubble Media article about Chain, someone had created similar, competing articles that, while containing much of the same content, painted Chain in a more positive light.

I previously mentioned this to Jacob Silverman: Chain.com today is not the same entity (or people) that ran Chain.com ten years ago. For the bulk of the 2010s, Chain.com attempted to play its hand in the “enterprise” blockchain world and eventually was acquired by Stellar. Someone else bought the domain name a couple years ago. But that’s not clear from the the language in the passage above. For example, is Adam Ludwin still involved? Seems unlikely.

On p. 209 they write:

Jacob confronted Chain’s CEO via Telegram. He denied ever having heard of Mevrex or hiring them. Eventually, after a fair amount of badgering and pleading with communications people at the respective companies, James’s Twitter and Substack accounts were restored.

What did Jacob say? What did James say?

On p. 210 they write:

They also treated their critics—some of them simply well-meaning customers who wanted to know how their assets were being handled—with utter derision.

This is a good point. One notable example was Mashinsky responding to Mike Dudas.

Source: Twitter

On p. 210 they write:

Every time Mashinsky accused his evil critics of spreading FUD, I assumed that DBM was probably on the right track. The proof was often in the block-chain data, waiting to be interpreted.

Why is there a hyphen in blockchain?

The discussion on KeyFi’s revelations on p. 211 was good, seems like everyone was happy when NGU but when it doesn’t, they spill the beans on social media.

On p. 214 they write:

As for James Block, who eventually revealed his name after journalists began peppering him with requests for tips and commentary, he was offered a job by a hedge fund shorting crypto. He decided to stick to medicine.

Out of curiosity was the hedge fund Hindenburg Research? The same ones who announced a $1 million bounty on Tether that as of this writing no one has claimed? Or was it Citron Research, the fund that announced it was shorting Ethereum and then days later deleted their thread?

I’ve often wanted to short a variety of coins and tokens but the counterparty risk was one of the main reasons I haven’t.80 Perhaps this is part of the reason why Perpetuals are popular?81

On p. 216 they write:

James sounded the alarm on Celsius, but few wanted to listen.

I think James Block did a great job highlighting numerous red flag as Celsius. And there were others, including Maya Zehavi, who publicly questioned Celsius’s model. Nearly two years ago Protos even highlighted one of Zehavi’s tweets.

And one on Hogeg that could be in the book:

Source: Twitter

Zehavi has at least a dozen Hogeg-related tweets pre-2020. A second edition should give her a well deserved podium.

What would have made this chapter in particular stand out is if it included some diagrams showing the flow of funds that James Block and others identified. The prose was decent too. Definitely seems like the chapter with the fewest errors or mistakes.

Chapter 12: Chapter 11

Source: Kindle

There was a minor technical glitch in the Kindle version, it is missing the subtitle.

Overall this chapter is a bit dry in large part because it relies almost entirely on second-hand reporting. They do have a few new original quotes from SBF but none of those seemed particularly incriminating.

The authors also missed a couple of comparisons when it comes to evaluating intermediaries.

For instance, on p. 217 they write:

Accounts on FTX US were of course not FDIC-insured, as FTX US is not a licensed US bank but rather a money services business, which doesn’t offer customers the same protections.

This is a good point. A similar (misleading) claim was made by Robinhood five years ago. In December 2018 the CEO publicly claimed that user deposits in new checking accounts were insured by the SIPC only to have to walk back the claims after the head of the SIPC (and others) pointing out that this was not technically true.

On p. 217 they write:

Like so many interactions in crypto, it was a messy and unsatisfying affair. However, it did reinforce one thing: Sam was desperate to stage-manage his public image. The dark arts of PR were part of any actor’s Hollywood education, and Sam clearly needed more lessons.

What are the dark arts of PR? Is McKenzie saying he too was involved in the “dark arts of PR”?

On p. 219 they write:

Over Twitter DM, Sam spoke darkly to me of a coming conflict dividing the industry. Binance was pushing its customers to convert their stablecoins into BUSD, Binance’s own dollar-pegged token. “It’s the beginnings of the second great stablecoin war,” he messaged me on September 5. “All the stables are gearing up for it. Taking this as a declaration of war.”

This is interesting. For illustrative purposes a timeline could be helpful to readers to understand when the first, second, third, etc. “stablecoin wars” supposedly took place. Also, when SBF said “all the stables are gearing up for it” did he provide any evidence for this? For instance, was TUSD or Dai backers involved?

On p. 220 they write:

That financial perpetual motion machine looked a lot like the Celsius “flywheel” concept that James had previously investigated, and that Professor Hilary Allen had warned about in February of that year.

It bears repeating: Celsius was a centralized lender. Connecting that with what Allen wrote about (“DeFi”) last year is disingenuous.

In contrast, here’s what I had to say in June 2022:

There’s not need to cite me, but if you are going to critique the coin world, at least try to accurately describe what is and is not centralized.

On p. 220 they write:

According to bankruptcy filings, FTX/Alameda lost $3.7 billion before 2022. Quite impressive to lose that much in a bull market!

This is a good point.

On p. 227 they write:

As last month’s scammers came in from the cold to yuk it up on social media, the post-SBF positioning became frantic—who was to blame, who supported him, who failed to warn the public. Even us crypto skeptics got our turn in the dock—apparently our frequently repeated claims that the entire industry was built on bad economics, bad incentives, and outright fraud wasn’t enough.

What is a “crypto skeptic”? Do the authors speak on all of their behalf?

On p. 228 they write:

Some claimed to have held back for fear of angering a powerful industry player. Bitcoin maximalists blamed Sam for all their problems, rightfully pointing out SBF’s cozy relationship with mainstream media publications, regulators, and lawmakers (some of which he gave large sums of money). But then, as maxis are wont to do, they wandered off into wackadoodle land, painting conspiracy theories that Sam was working with Biden to send money to Ukraine via crypto.

What are Bitcoin maximalists? What are maxis? I have seen it but in the next edition can the authors provide a reference for the conspiracy theory?

On p. 229 they write:

Rep. Emmer was hopeful that further discussions might let them proceed with legislation that would allow for a “light touch” when it came to crypto regulation. The Blockchain Eight encapsulated so much of what was wrong when it came to Washington’s cozy ties to the industry. Evenly divided between Democrats and Republicans, five of the eight members received campaign donations from FTX employees.

I mostly agree with this. But I think there is arguably an even more damning example: a couple of the “Blockchain Eight” attempted to overturn the results of the 2020 presidential election. To use blockchain parlance, those would be Byzantine actors.

On p. 230 they write:

Legitimate technology companies like Microsoft belatedly summoned the bravery to admit that actually, when you really think about it, blockchain sorta sucked. It had no substantive use case. All the money spent to explore how maybe crypto might actually do something in the future had been wasted. Numerous other blockchain “pilot projects” quietly folded, including one by the Australian Securities Exchange.

There is a kernel of truth in this paragraph. For instance, in May, ASX said it would not use a blockchain for its CHESS-replacement endeavor (which was spearhead by Digital Asset). And there have been quite a few pilots and experiments that tried and failed to gain product-market fit or infrastructure-market fit. I’ve written about several of these cases (including the Chain.com of the 2010s).

But the rest of it is just polemical in the same vein as Diehl et. al. When did Microsoft belatedly say “blockchain sorta sucked”? As of this writing, their Azure department has an entire Web3 team still actively involved in the blockchain world.

But let’s take the authors unreferenced claim at face value, that there is no substantiative use case discovered by Microsoft or other “legitimate technology companies.” So is that the end of the blockchain story?

Putting aside for the moment that the authors have shown an affinity for incumbents, why should readers be led to believe those are the only participants allowed to have opinions on the matter? One of the key weaknesses of this chapter, and book, in general is that the authors attempt to have it both ways: they sometimes attempt to use evidence when it helps their argument but then resort to an a priori cudgel in other instances. The next edition needs to have consistency (e.g., remove the a priori arguments).

A better argument would have been to reach out to the “head of blockchain” at Microsoft (currently Yorke Rhodes) and do some first hand reporting about what that organization has done and why they apparently think “blockchain sorta sucks.” Maybe it does! But let’s at least be methodical about dressing it down.

On p. 233 they write:

The chairman of FBH was none other than Jean Chalopin, the chairman of Deltec Bank, whose most infamous client was Tether. As the New York Times noted, “Farmington’s deposits had been steady at about $10 million for a decade. But in the third quarter this year [2022], the bank’s deposits jumped nearly 600 percent to $84 million.” The bank was renamed Moonstone. Its digital director was Janvier Chalopin, son of Jean.

So what exactly is the crime? That there is nepotism at a bank called FBH (Moonstone)? Should sons or daughters be able to run banks their parents previously ran? If not, should the Rockefeller and Morgan families be looking over their shoulders? Insinuation and innuendo is all the authors have here?

On p. 235 they write:

On December 16, just over one week after releasing its report on Binance’s holdings, Mazars announced—via Binance—that it was exiting the business of auditing crypto companies “due to concerns regarding the way these reports are understood by the public.” The company deleted its website with its reports on Binance and other crypto firms.

Oof, that’s a good point. I think one of my favorite audit-related stories was shortly after Bitfinex was hacked (the 2nd time) Michael Perklin was brought in to conduct an audit. But then he quietly left and joined Shapeshift. No audit was made available to the public.82

On p. 237 they write:

The Trump NFT collection—45,000 silly cartoonish portraits of the former prez looking cool and badass—sold out in a day at ninety-nine dollars apiece, likely netting him millions.

“Likely”? Perhaps Donald Trump lied in his filings, but according to a CoinDesk story in April 2023, he earned between $500,001-$1 million on NFT sales. Is that a lot or a little?

On p. 237 they write:

That system eventually became an engine of economic inequality and political alienation. Crypto was right about that. But their solution—to create a private, trustless financial system based on code, unstable digital assets, and a new class of intermediaries—fell apart under its own contradictions, including rampant opportunities for fraud. Crypto had indeed produced something no one could trust, and Sam Bankman-Fried, their knockoff J. P. Morgan, would be remembered as one of its architects.

This is not a strong argument. For example, what happens if incumbents end up using blockchains in the future? Are intermediaries okay so as long as they are incumbents?

It’s also unclear why the authors keep using a false dichotomy. Investigative journalists don’t have to carry water for anyone. And in this instance, it is perfectly fine to critique both the cryptocurrency world and traditional finance.83

This could have been a good chapter. For example, they did do a decent job concisely chronicling some of the drama (and beef) between Binance and FTX. But the tone of it all feels like self-promotional “told ya so” which is strange because neither author was actively investigating this space until late 2021, after the alleged crimes began at the various centralized intermediaries. A future edition could fold this together with the outcome of the current SBF criminal case.

Chapter 13: Preacher’s Father

This chapter probably should have come much earlier because it told a really interesting, sad story that the authors did some first-hand reporting on. The problem is that its somber tone is polar opposite of the stoner tone of the first few chapters. While the authors were quite glib about discussing McKenzie’s pot smoking/edible habit, at the end of the book the readers get some whiplash with McKenzie sitting in church listening to a sermon from a son of a fraud victim. Although to be fair, I’m not religious so maybe I’m being overly sensitive relative to other readers.

A future edition could probably keep the entire chapter intact, as it was well-written and involved a relatively unknown (alleged) fraudulent operator: Stallion Wings.

With that said, there are a few nit picks.

On p. 246 they write:

They come in wanting to limit their downside, but end up doing the exact opposite—they chase their losses until the money is gone. The vast majority end up losing money because the forex market, just like a casino, has a negative expected value.”

This could be true – and anecdotally I think they could be right – but the authors do not provide any references (in fact, there are only 2 references for the whole chapter). That which is asserted without evidence can be dismissed without evidence. Also, as mentioned earlier, some trading platforms in the forex (FX) market also allow high leverage to retail (beyond 125x).

On p. 247 they write:

The volatility of crypto and the high leverage offered to retail customers add to its addictiveness. With wild swings in price, a well-placed crypto bet can be intoxicating, euphoric. Add to that leverage—essentially the ability to borrow large sums to bet with—and the highs get even higher. Recall that Binance offered regular customers 125-to-1 leverage, a ratio unheard of in regulated markets.

A future edition should include the meme of Mark Karpelès, former ex-CEO of Mt. Gox:

Again, there are regulated markets (FX) that allow for that type of ratio, just google: Forex leverage. MultiBank Group immediately pops out, are they legit? Should FX markets be more tightly regulated?

On p. 252 they write:

The original computer code that would become Bitcoin included a poker lobby, a framework from which a virtual poker game could be built. Whoever Satoshi Nakamoto was, in early 2007 they were clearly interested in methods of creating non-confiscatable digital money and how they might be used in online poker.

I agree with this point. And over the years, there are at least five cryptocurrency developers who have publicly said something similar, albeit for different reasons: Matt Corallo, Greg Maxwell, Jeff Garzik, Alex Waters, and Jackson Palmer. There are a number of threads on reddit and Bitcoin Talk that also discuss this scenario.

Their concluding paragraph of the chapter, on p. 255 reads:

Each generation of tech and financial “innovators” promise their own form of utopia, and crypto advocates have had their turn to demonstrate theirs, with all of its attendant failings. Like so many of its Silicon Valley venture capitalist forebears, the crypto industry’s vision is fundamentally a selfish one, divorced from any real sense of how the world works and what is required to bring us together rather than pull us further apart. We cannot eradicate the need for trust, and it is not just wrongheaded, but fundamentally nihilistic to aspire to do so. In the end, we have only ourselves and each other on whom we can rely.

I agree with the first sentence and have written about “Innovation Theater” before. But it is a strawman and inaccurate to portray “the crypto industry vision” as a unified something. Sure there are a variety of camps that sometimes lobby together, but they can’t claim to speak “on behalf of crypto” anymore than the authors can claim to “speak on behalf of critics.” It’s disingenuous and happens throughout the book.

Ironically while the authors attempt to hammer home the importance of “trust,” throughout the book they do not cite sources for a number of their claims. Verify, not trust.

Overall it was an okay chapter, albeit a bit preachy which is sort of fine considering it partially takes place in a church. Perhaps the biggest drawback from this chapter and the book altogether at this point is that the authors do not provide any solutions to prevent fraud or restore those who have been defrauded. That is a missed opportunity.

Epilogue

This epilogue is pretty self-serving, it is basically describes McKenzie as some kind of maverick who tells truth to power. It’s cliché and does not really cover new ground. It makes sense to have an epilogue for this type of book but its tone seems out of touch with the victims described in the previous chapters.

On p. 257 they write:

It was December 14, 2022. I was testifying before the Senate Banking Committee on the collapse of FTX/Alameda and what it meant for crypto, and for the millions of investors who had lost money in the process. On the other end of the panel was Professor Hilary Allen, whose February paper had anticipated crypto’s collapse.

How many millions of investors lost money from the collapse of FTX and Alameda? Did they mean to write customers?

Also, Allen’s paper did not anticipate “crypto’s collapse.” She incorrectly predicted DeFi lending protocols would collapse, and they did not whereas centralized lenders did. Maybe Aave and Compound will eventually face some kind of existential cataclysm, but as of this writing they have not.

On p. 257 they write:

Professor Allen and I had been invited to describe the myriad ways in which crypto’s epic collapse was entirely predictable and why the time for such shenanigans is long past.

I think the readers would be interested to know who invited McKenzie and Allen, just like we would like to know who invited Schulp and O’Leary. There are an endless amount of folks who probably want to testify to a Congressional committee. There are also a number of experts worth adding to the dais that have unimpeachable on this topic, including J. P. Koning and David Andolfatto.

On p. 258 they write:

“Mr. Wang created this back door by inserting a single number into millions of lines of code for the exchange, creating a line of credit from FTX to Alameda, to which customers did not consent,” claimed FTX lawyer Andrew Dietderich. The innovative wonders of “trustlessness” and “decentralization” were on full display.

This is a strawman. FTX and Alameda were centralized intermediaries, by definition neither were decentralized.

On p. 258 they write:

Add a single number to millions of lines of code, and voilà, one can siphon billions in “loans” from accounts held by regular folks oblivious to the swindle. Trust the code, indeed. Dietderich continued: “And we know the size of that line of credit. It was $65 billion.” Bernie Madoff’s Ponzi was $64.8 billion.

Another strawman. The code that ran this part of FTX was written for the intermediary, not a blockchain, and it was managed on github. And again, both Alameda and FTX are centralized intermediaries. Neither was a blockchain nor a smart contract. The authors are insinuating that the code that runs DeFi protocols, such as Aave, have some kind of giant exploitable whole on par with Madoff’s Ponzi or FTX. Maybe they do, but the authors need to be specific next edition. That which is asserted without evidence can be dismissed without evidence.

On p. 259 they write:

I’d gotten into several public Twitter spats with journalists at The Block who questioned my understanding of the industry they supposedly covered honestly. They were less voluble now.

Is it possible that both are true? That certain coin reporters are shills and that the authors do not have a good understanding of the subject matter?84 For instance, in all but one chapter the authors conflate Bitcoin with “crypto” (broadly) and do not provide definitions or examples of “DeFi.”

On p. 263 they write:

While the speed of the failures was alarming, I couldn’t help but notice that two of the three collapsed banks had significant exposure to the volatile world of cryptocurrency, and the third (SVB) counted as clients the crypto companies Ripple, BlockFi, Circle, Avalanche, and Yuga Labs, among others.

Steven Kelly and Todd Phillips are academics that should be included in a future edition as they discussed these bank failures in real-time.85

Readers may be interested in the Appendix of my March 2023 presentation on the topic as well.

On p. 264 they write:

The other major player left standing was Tether. The stablecoin company, valued at $71 billion as of March 1, 2023, had miraculously survived while the industry around it bit the dust.

As mentioned at the beginning of this review, this is not the correct valuation of the company. The authors mistakenly conflate the aggregate amount of USDT issued with the book value of equity of the issuing company (Tether LTD). Tether LTD is worth a fraction, in the low billions

On p. 264 they write:

Per Bloomberg, “Bitfinex Chief Technology Officer Paolo Ardoino said in an interview he sees enough demand for El Salvador to issue the full $1 billion it is seeking.” Where this demand would come from was anyone’s guess.

I am skeptical of that claim too but the authors are reporters: they are supposed to find out where that demand is. For example, in Chapter 7 I noted that following the book’s publication there was a 180% rally in El Salvadorian government bonds. The following month, in August, Bloomberg ran a headline Bitcoin-Touting Bukele’s Bond Rally Draws JPMorgan, Eaton Vance.

On p. 265 they write:

The issuance of the Bitcoin Bond was itself fraught with consequences for the local population. Wilfredo Claros, the fisherman I visited the previous spring who lived in the hills above La Unión, would soon be forced to abandon his home and his land so the airport servicing Bitcoin City could be built. According to Wilfredo, the government offered him one-tenth the amount he had requested in exchange for his property.

This is probably what the epilogue should have centered around: the victims. The people who got screwed by the SBF and Mashinsky.

A future edition of the Epilogue could focus more on “where are they now” — the stories of the El Salvadorians are interesting!

Acknowledgements

Even at the end, we still do not have a precise definition of a “critic” or “skeptic.”

On p. 269 they write:

To the members of the crypto skeptic community, I want to thank you for your friendship, tutelage, and guidance along the way. Unfortunately, it would be impossible to list all the skeptics who have helped me over the past two years, but I do want to thank a few of them specifically.

Is there a formal organization for supposed “crypto skeptics”? Or the “cryptos skeptic skeptics”?

The authors then list off eight names, none of whom are blockchain technical experts (although one worked for a smart contract-related company, which he removed from his LinkedIn). Did the authors reach out to any of hundreds of engineers that eagerly respond to social media questions on this topic? If not, why eschew actual experts?

Why interview actual experts when you can chat with social media influencers!

On p. 269 they write:

Thank you to Hilary Allen, Lee Reneirs, Rohan Grey, Eswar Prasad, and John Reed Stark for helping me understand American law as it relates to cryptocurrency, as well as the history of financial regulations in the US.

As mentioned in Chapter 10, they misspelled Reiners last name and didn’t cite any of his work. Strangely, even though they name check Rohan Grey, they don’t cite any of his work either, despite having co-authored the STABLE Act and opined on centrally-issued pegged coins on numerous occasions.

Appendix

This is a copy/paste from the SEC website.

Conclusion

In retrospect, seeing as how much it has been used as a marketing term, perhaps I should have trademarked both “crypto critic” and “crypto skeptic” back when I was first called them.

This was not a good book. It should have been, as it had a good publisher and the market clearly needs a book exploring what went wrong during the bubble years. But the authors made a lot of unforced errors, including getting too close to their sources, that could have been fixed through independent fact-checking.

What’s one example?

Let’s start with the Author’s Note at the very beginning:

What follows is my opinion of the events as I perceived them over the nearly two years I spent down the crypto rabbit hole. Throughout the book I use terms like “fraudsters,” “conmen,” “swindlers,” and “scammers” in reference to various actors in the crypto industry. These descriptors are nothing more than shorthand for my opinion. I don’t mean to imply that any particular person, in fact, broke a law or violated a regulation. In a similar vein, not everyone who works in cryptocurrency has poor intentions. While we may disagree wildly as to crypto’s usefulness, they have not committed fraud. It is my hope they will join me in condemning those who have.

Despite this disclaimer, the authors regularly claim – without facts – that such and such is a security or some entity broke a law. Sure everyone is entitled to an opinion, but using nuance-free language, and strident certainties is at odds with this Author’s Note.

There was no substantive technical criticism.86

For example, the authors missed the opportunity to discuss the critical role Lido currently plays in the Ethereum universe. What role is that? That’s what the authors should have figured out.

Or how centralized and dependent L2s currently are on sequencers. What’s a sequencer?

Or how MEV has evolved overtime. What is MEV? How do frequent batch auctions (such as those used in CoW Swap) reduce the impact of MEV?

Source: Threads

I mostly agree with Benedict Evans observation above. It seems clear from this book that the authors misunderstand the subject matter, otherwise they wouldn’t have made as many mistakes. This includes conflating all “crypto” with Bitcoin or failing to provide a single example of a DeFi dapp or not explaining what staking is or what a block maker is or not knowing that PayPal operates as a shadow bank (now with two types of “dollars”).8788

Furthermore, by endorsing Hilary Allen’s thesis, this also dings their credibility. Recall Allen predicted that DeFi lending protocols would collapse during a crisis. Aave and Compound did not collapse like she predicted. In fact, it was the centralized lenders that blew up last year. Perhaps these DeFi lending protocols will face a day of reckoning, but they do not suffer from the rehypothecation problem in part because all of the collateral is locked on-chain.

The authors routinely impeach their credibility by purposefully crumbling up NDAs and intentionally keeping the audio recording after an interview is done. This smells more like gotcha journalism which is lazy especially since nothing new was revealed in the process.

As a consequence, the book should probably be renamed: Blockchain Tourists. Is that unfair?

The jaunt down to Rockdale Texas seems to have resulted in little more than a photo-op for the authors. Did they help close down Riot’s Bitcoin mining facility?  Have they subsequently attended any of the local hearings or spoken with anyone during the “week of action” like Peter Howson did?89 Note: Howson is the author of the newly released: Let Them Eat Crypto

And while you can’t always time the publish date of the book, Easy Money had the misfortune of being released just before Zeke Faux’s Number Go Up, which was superior in all dimensions. 90 If you have to choose between the two, I can definitely recommend Faux’s version of events. See my review of that book here.

Endnotes

  1. In Number Go Up, Zeke Faux also writes his book in first-person, but doesn’t make the story about him. []
  2. For example, were the authors aware that one of the events McKenzie attended was a front for BSV? []
  3. By the end of Q3 2023, tokenized U.S. Treasuries hovered around $665 million. []
  4. In contrast, Zeke Faux noted this episode on p. 212:

    If you’re having trouble following this, that’s actually a good sign about your investing instincts. Comedian John Oliver later summarized Do Kwon’s nonsensical business plan: “One blorp is always worth one dollar. And the reason I can guarantee that is I’ll sell as many fleezels as it takes to make that happen. Also, I make the fleezels.”

    Strangely the authors did not include any history – abridged or otherwise – on the zany world of ICOs. This is puzzling because the infrastructure enabling Tether (USDT) was Mastercoin, one of the first projects to use the ICO model to kickstart itself. In contrast, Zeke Faux discusses it at length on page 49. []

  5. Fun fact: in January 2018 I spoke with one of the producers of that John Oliver episode and provided some fact-checking and clarification. []
  6. CMC also has a little 2m+ figure in the top left, that clearly is larger than the figure the authors use. []
  7. Hayden Adams, co-creator of Uniswap, has previously mentioned that on an average day 5-10 new coin pairs are added to Uniswap by random developers. []
  8. For instance, Meltem Demiror’s appeared on CNBC in a now deleted segment mentioning XRP. All of that was memoryholed, promoters ended up with coinesia. []
  9. Speaking of which, does everyone remember when Anthony Pompliano stopped using “The Virus is Spreading” as his catch phrase circa March 2020? []
  10. Jeff Garzik got on an airplane in order to receive one of the first Avalon ASIC miners. []
  11. For instance, Chapter 4 of my 2014 book literally is titled: The Red Queen of Mining. In Chapter 6 of “The Age of Cryptocurrency,” Michael Casey made a similar mistake. []
  12. In 2014, during a now deleted podcast episode (#116), I had a chance to debate co-hosts Stephanie Murphy and Adam B. Levine regarding on-chain activity, including gambling from Satoshi Dice. See: A Marginal Economy versus a Growth Economy []
  13. The authors could have easily dunked on garbage metrics such as cumulative addresses or wallets, two figures that only goes up no matter what. For instance, over eight years ago I published: A brief history of Bitcoin “wallet” growth. A few days later, an employee at BitGo contacted me for help to identify which wallets were “real” versus one-time burners. That was a job for an analytics company. []
  14. For comparison in Number Go Up, Zeke Faux uses the term “crypto bro” (15 times) which is a term I and other writers have used to describe specific coin promoters. []
  15. Marc Hochstein unfortunately normalized its mainstream usage. []
  16. For instance, during the block size civil war in 2015-2017, a number of the the Bitcoin Cash/XT developers wanted to significantly increase the block size in order to pursue a payments-focused roadmap. Who was right or wrong? Well empirically we have seen Bitcoin Cash successfully upgrade to 32 MB blocks, but these are mostly empty blocks because in practice, most BCH holders seem to want to hoard their coins instead of use them for payments. []
  17. We moved three times in the span of ten months, all with a one-year old in tow. []
  18. The Fed proposed cutting the current cap from 21 cents per transaction to 14.4 cents per transaction. []
  19. Readers may enjoy: Everything Everywhere Is Securities Fraud by Matt Levine. []
  20. In theory, AMMs could be used in traditional finance too. See: Automated Market-Making for Fiat Currencies by Alex Lipton and Artur Sepp. []
  21. It is likely that the authors of several other books I reviewed also had some undisclosed investments. One that comes to mind was Chris Burniske in Cryptoassets. []
  22. For what it is worth, there have been dozens of times where I wanted to short a specific coin or token, but it was hard to trust the counterparty (the CEX), so I never did. I empathize with his motivation, but he should have disclosed the bet(s). []
  23. I wrote long newsletters outlining the antics and shadiness of parts of the coin industry. []
  24. This past summer, McKenzie trolled the birdapp by saying “have fun staying poor” as well. []
  25. See also: Will the real stablecoin please stand up? by Anneke Kosse, Marc Glowka, Ilaria Mattei and Tara Rice []
  26. Tokenization attempts have expanded beyond precious gems and metals. In 2021, Poolin, at the time one of the largest multi-cryptocurrency mining pools, released a “hashrate token” which as the name suggests, attempts to tokenize a discrete amount of hashrate generated by mining hardware. At the beginning of the year, Navier, a Bitcoin hosted mining services company, announced a similar effort for “qualified investors.” []
  27. On p. 96 the authors mention White & Case. Coincidentally, this was the law firm Bob – a U.S. trained lawyer – worked at prior to joining the coin world. []
  28. The STABLE Act, co-authored by Rohan Grey, provides legislative latitude for the erection of a narrow bank-like structure that currently does not exist but likely best fits the needs of an entity like a pegged-coin issuer. []
  29. For some reason Silverman has deleted every tweet he ever engaged with me on as well. Unclear when this occurred; is this common for reporters at The New Republic to do? []
  30. For instance, two months ago, the U.S. Secret Service seized around $58 million belonging to Deltec from MUFJ. Why does it matter if the creator of Inspector Gadget founded Deltec? Is there only a specific category of people who are allowed to create banks? It is a distraction for readers who should have been informed more pertinent details like what Forbes reported in January. Perhaps this is a little unfair, as the authors had to ship a book and missed some news (they were still updating this book in January and the Epilogue appears to be written in March). Either way, the book was light on details for Deltec which does seem like an interesting bank to look into and Zeke Faux did so in Number Go Up. []
  31. I previously mentioned his real name back in February 2022 in section 5. []
  32. I am not sure who first coined the term “Tether Truther” but I have used it in the past to describe people who still claim – post-CFTC settlement – that Tether LTD is still acting in a fraudulent manner. The “Truther” modifier is similar to the scheming intrigue of other “Truther” movements. USDTQ is a riff on the conspiratorial TSLAQ. []
  33. “Cut to the chase” is an apt expression here. In contrast to Faux’s book (which does discuss Tether at length), McKenzie and Silverman linger and beat around the bush. Part of the issue likely stems from the fact that they have cultivated sources, such as Bitfinex’ed, who have no insider information. []
  34. It seems USDT-related development is about the only thing active on Liquid at the moment. []
  35. See 40 cointroversies to look into over the summer []
  36. Gee, I wonder what cowardly “Boston Celtics” fan who loves to setup alt accounts saying the same thing “This You?” to the same exact people, could be. []
  37. On p. 50 Faux writes: Phil Potter, an executive at an offshore Bitcoin exchange, Bitfinex, was developing a similar idea. They teamed up and adopted Potter’s name for it: Tether. (Potter told me he was actually the one to first approach Sellars with the idea. “I’m sure Brock will tell you he came down from Mount Sinai with it all written on stone tablets,” he said.) []
  38. Many SPACs deserve scorn because in part, some screwed over retail and it was odd that Diehl et al. treatment on this topic did not mention SPACs at all. []
  39. One response could be that Zeke Faux, on p. 199 of Number Go Up, mentioned being part of the “crew” for The Mutant Cartel, but it was clear to readers that the mutant ape he purchased was to be temporarily used as a guest admission ticket, not some permanent band-of-brotherhood. []
  40. For instance, I have publicly stated many times that I am in favor for allowing anyone that wants to opt-in to have an account with the central bank. See section 2 in Was 2021 the year the coin world went from edgy to banal? []
  41. It is worth looking at the E-Cash Act too. []
  42. According to Bowden et al., actual block propagation (arrivals) do not follow the (theoretical) homogenous Poisson process that was expected upon its release in 2009. []
  43. Kofner is the author of the widely cited comparison between transferring funds with Bitcoin versus several “traditional” wiring services. It debuted in 2014 and is still updated on a regular basis. []
  44. Newstat tweeted out his identity and then did a “reveal” podcast with Tomlinson wherein he made a number of false statements about myself. Unfortunately neither McKenzie nor Silverman reached out to verify if any of the claims that Newstat had made were valid (or not). And subsequently McKenzie falsely accused me of harassment. Then he blocked me. It would be a massive distraction to this book review if we were to litigate all the finer points of this drama. In reading this book it is clear that they were all pals, so closing ranks makes sense, but that is not what a reporter is supposed to do. Verify, not trust. []
  45. I recall a DC-based reporter recently tweeting that if a reporter feels the need to befriend their sources, they should probably just get a pet instead. []
  46. An interesting post-trade infrastructure story – about the DTCC and Cede and Co. – was written more than six years ago: Dole Food Had Too Many Shares by Matt Levine. []
  47. Coincidentally, in the process of writing this review the DTCC acquired Securency, to help with their tokenization efforts. []
  48. Note: I strongly disagree with Gladstein on many things but do find it strange that the SBF segment wasn’t released, surely it would be good promo material? []
  49. While it is possible to lever up with white-listed collateral on DeFi lending protocols such as Aave and Compound, the amount thus far is magnitudes less in part because of capped LTV ratios. []
  50. Between 2014-2019 I met a whole sundry of people claiming to work for some kind of agency including the FBI and InQTel. Didn’t drink with them though. []
  51. Seems like this purity contest over who is the most OG “critic” is stolen valor. And the supposed award nominations? Jumping the shark. []
  52. Dozens of U.S.-based Bitcoin mining companies recently visited Washington D.C. to lobby and spin the narratives away from P-o-W being an environmental blight. A second edition could look at these types of efforts. []
  53. The authors could have highlighted that some bad actors never leave the coin world. For instance, Michael Patryn – co-founder of defunct exchange Quadriga – was revealed to be Sifu. Patryn/Sifu were in the news last year for forking Aave. []
  54. Coincidentally, in the process of writing this review, FX retail trading in Japan – which accounts for the largest market share globally – hit a record high. []
  55. Not an endorsement but there are attempts to build self-custodial exchanges in the DeFi world, such as C3. []
  56. Look no further than the Board of Directors at registered clearing agents to illustrate possible synergies and conflicts. []
  57. Derivative liquidations in traditional finance is now less brazen in how it screws end users. For instance, in the UK, retail traders of spread-betting and CFD products often lose all capital in 3-6 months. As a consequence the FCA has honed in on changes to advertising CFDs the past four years which includes restricting the sale and how they are marketed. []
  58. Coincidentally, I co-authored a peer-reviewed paper that intersects with this topic: Decentralized Financial Market Infrastructures: Evolution from Intermediated Structures to Decentralized Structures for Financial Agreements []
  59. I have publicly asked it as well, for instance, on November 30, 2017. []
  60. Also, doesn’t the former Chief Strategy Officer – Phil Potter – live in New York City? []
  61. Laura Shin recently interviewed two creditors of Genesis who deposited more money following assurances from Genesis. []
  62. See Tribes of maximalism []
  63. To hammer this point home, nearly two years ago, BSTX, a joint venture between tZero and Boston Options Exchange (BOX) Digital Markets, received approval from the SEC to operate a blockchain-based securities exchange. Maybe BSTX fails to gain traction, maybe the market doesn’t care about blockchain-related exchanges. But the issue at the heart of Mirror wasn’t “the exchange” existed; the problem was the fraud, not the existence of a new trading venue. []
  64. Allen also made a number of incorrect claims regarding Ethereum’s “Merge” last year. []
  65. Allen was wrong in part because according to her acknowledgements she seems to rely on Stephen Diehl for technical assistance. Here is a my book review on Diehl’s book, the most inaccurate blockchain book I have ever read. []
  66. I sent an email to Hilary Allen on February 20, 2022 that included a number of comments in her draft, it does not appear that she incorporated any of the suggestions including the correction to the false claims about new tokens being used as collateral for loans. []
  67. Over the past 15 years it acquired Lehman Brothers, Washington Mutual, and WePay. The former two during the duress of the financial crisis. J.P. Morgan is also a partial owner in Maxex, a mortgage clearinghouse; payments consortium “The Clearing House”; Cboe Clear (in Europe); and other infrastructure that might meet the criteria of “conflicts of interest” albeit at arms length. []
  68. Lack of by-lines: one of the reoccurring themes within the Protos world is to dunk on anonymous Tether promoters and shell companies, yet the publication allows anonymous contributions. This is a double-standard, having your cake and eating it too. []
  69. According to its Chapter 11 bankruptcy filing last year, Alameda had outstanding liabilities of $5.1 billion. But putting aside those loses, I could conjure several explanations. []
  70. One interesting nugget the public learned during the SBF criminal trial is that Caroline Ellison testified that she produced multiple different balance sheets, all of which were false. The one that was leaked to CoinDesk in 2022 was one of the rosier balance sheets, yet was itself fudged too. []
  71. See also Crypto adoption in America by J.P. Koning []
  72. This is not an endorsement of RWAs. At least one lawyer has argued: that the point of blockchain is to reduce trust assumptions/requirements and in almost all current cases, “tokenizing RWA” increases trust assumptions far above those even required for normal off-chain ownership. As a researcher this is why I have found it strange that some DeFi dapps parasitically rely on off-chain collateral (centrally issued pegged coins). Readers may be interested in this relevant thread from Andrea Tosato. []
  73. Zelle is operated by Early Warning who partnered with The Clearing House a couple of years ago. []
  74. On October 10, 2022 the USDD “marketcap” was about $795 million, a year later it was roughly $728 million. In contrast, according to ChainArgos, “Overall USD stablecoin market cap on ethereum down roughly $4 billion on ethereum and up more than $5 billion on Tron over the last 90 days.” []
  75. Some of the people the authors cited in this book did some grave stomping when FTX collapsed. But as we have seen in the criminal court case of SBF, apart from a handful of insiders no one actually knew what was going on. []
  76. The case has not gone to trial yet, but Saylor did lose a bid to quickly quash the suit. []
  77. Having spoken to Walch about the current batch of “skeptics” and “critics” – which she has been labeled in the past – it is pretty clear why neither of us amplify people who market themselves as such on social media. []
  78. Following the Hamas terrorist attacks, Stark dinged his credibility in a pair of sensationalistic tweets. He states that “crypto is not traceable” yet relies on ChainArgos which uses analytics to link addresses. Contra Stark, in this case, something is indeed traceable. Two chain analytics companies wrote rebuttals to this specific sensationalism: Chainalysis and Elliptic. Also, the authors of The Wall Street Journal article Stark cites mistakenly counted an entire exchanges’ trading volume (~$82 million) for a terrorist group’s address. Even the U.S. Deputy Treasury Secretary Wally Adeyemo weighed in on the topic. []
  79. One example of the “Horseshoe theory” in practice — the observation that some Bitcoin maximalists and anti-coiners both use an anti-empirical, a priori cudgel — is to look at say, Stephan Livera’s list of guests. At one point the running joke was that his dozen repeat guests each had podcasts whereby the only invited one another, because that was the size of their maximalist clique. In some ways we see that form of insular “in-group” dynamic in this book wherein the majority of “critics” or “skeptics” are the ones who pass one another’s purity tests. []
  80. In Number Go Up, Zeke Faux spoke with several hedge funds that wanted to short USDT. On p. 92 he writes: “I’m betting a shit-ton of money on them being a crook,” Fraser Perring, co-founder of Viceroy Research, told me. “Worst case is, I can’t lose hardly anything. I’m already rich, but I’m going to be fucking rich when Tether collapses.” []
  81. Perpetuals has become a catch-all term for a category of futures. These products often have higher daily trading volume that spot trading on centralized exchanges. Cam Harvey put together a quick primer on the topic. The original idea dates back three decades, from a paper by Robert Shiller. []
  82. As I mentioned at the time: For instance, on August 17, 2016, Bitfinex announced that they had hired Ledger Labs who, “is undertaking an analysis of our systems to determine exactly how the security breach occurred and to make our system’s design better going forward.” According to one post, Michael Perklin was the Head of Security and Investigative Services at Ledger Labs and part of the team leading this investigation. However in January 2017 a press release announced that Perklin was joining ShapeShift as the Chief Information Security Officer; his profile no longer exists at Ledger Labs. 18 Thus the question, what happened to the promise of a public audit? []
  83. The authors point out that during highly volatile periods, some CEXs suffer delays and/or shutdown entirely. They highlight a couple of possible reasons, including exchange operators being up to no good, which historically is a real possibility. To be even handed, even mature exchanges in traditional finance have (partial) shutdowns. For instance, in the process of writing this review the London Stock Exchange had a major technical incident which impacted (trading delays) small cap stocks for around 80 minutes. []
  84. Will certain crypto reporters from The Financial Times be held to the same standard they often criticize coin reporters of not reaching? []
  85. Coincidentally, during the process of writing this review, Phillips published a new paper directly related to the “securities” issue the authors referred to: Crypto Skeptics’ Supreme Risk. []
  86. Another missed opportunity was a discussion around privacy and confidentiality. For instance, the Zcash Foundation had its implementation of a threshold signature system reviewed by security professionals. Throwing the baby with the bath water, as this books authors frequently do, seems short-sighted. And this germane topic is not just relevant in the blockchain world either. For instance, Plaid normalized man-in-the-middle attacks. Will Akoyab continue this MITM normalization process? []
  87. A low-hanging point they could have made with proof-of-work mining: the block rewards are often value leaking from the ecosystem, to the benefit of state-owned energy grids and semiconductor companies. []
  88. Speaking of PayPal: is PYUSD just a marketing stunt? Which of the two different PayPal dollars is safer than the other? Will the frequency of the audit of the assets backing their other PayPal dollar be increased? []
  89. See also: Texans versus bitcoin: Jackie Sawicky and the Texas Coalition Against Cryptomining []
  90. For instance, while both books discuss Tether at length, Faux reached out to and received direct quotes from: Phil Potter (former CSO of Bitfinex) and from J.R. Willet (who created Mastercoin which is the infrastructure the USDT used on Bitcoin). Faux even corresponded with Arthur Budovsky, the creator of e-gold, who wrote back from prison. Did McKenzie and Silverman attempt to speak with these sources? []

Parasitic stablecoins

Leech - Wikipedia
Source: Wikipedia

[Note: this is a sequel to my previous post: Systemically important cryptocurrency networks, which critically examined how certain digital tokens parasitically leech off the U.S. banking system. There is an accompanying Appendix to this document as well.]

The second half of 2020 saw a large set of draft regulations and proposals surrounding cryptocurrencies and specifically, “stablecoins.”1

For instance, in July, the influential Group of Thirty published its investigation into digital currencies and stablecoins. In late September, the E.U. announced an expansive regulatory framework called Markets in Crypto Asset Regulation, or MiCA.2 A month later the Financial Stability Board (FSB), the top global stability watchdog, released its “final” report on what they called global stablecoins (GSCs). A month after that, the Bank for International Settlements (BIS) released a report specifically looking at stablecoins.

A few days later there was a flurry of tweets and articles written up in response to the newly proposed STABLE Act in the United States. And coincidentally, this past month the President’s Working Group on Financial Markets released a report on stablecoins that came out swinging against “multi-currency” projects like Facebook’s Diem (formerly Libra) as well as broad pieces of enabling infrastructure. 3

While each was written by different sets of authors in different jurisdictions, all had some common ground: regulation and risks of panjurisdictional commercial bank-backed “stablecoins.”4

This post will go through some of the background for what commercial bank-backed stablecoins are, the loopholes that the issuers try to reside in, how reliant the greater cryptocurrency world is dependent on U.S. and E.U. commercial banks, and how the principles for financial market structures, otherwise known as PFMIs, are being ignored.5

Let’s start in reverse order.

PFMIs

What are the PFMIs?

We have discussed the Principles for Financial Market Infrastructures (PFMIs) before. It is an evolving set of principles and guidelines for financial market infrastructures (such as CSDs, CCPs, payment systems) that are maintained and updated based on research and collaboration between two international regulatory bodies: BIS and IOSCO. Their joint 2012 paper is considered the gold standard and is frequently cited in the press, academia, and regulatory bodies.

For the purposes of this article, we will look at just once slice of the 2012 document. Principle 9 of the PFMIs states:

An FMI should conduct its money settlements in central bank money where practical and available. If central bank money is not used, an FMI should minimise and strictly control the credit and liquidity risk arising from the use of commercial bank money.

We have ample evidence from the 2007-2009 Great Financial Crisis (and other eras) that dependence on commercial banks is subpar and adding yet another (underaccountable) layer on systemically important financial institutions (SIFIs) is not ideal. 6

Without going into weeds, the PFMIs and the committees involved in drafting them, state and then re-state the importance of reducing credit risk exposure to commercial banks. Yet in all instances today, almost every collateral-backed stablecoin that has thus far been issued does so through tokenizing deposits custodied at commercial banks.

This is improper for a variety of reasons and there are remedies and solutions. For instance, while we await liberalized access to central bank digital accounts (CBDAs) or currencies (CBDCs), setting up “narrow banks” or FedAccounts have been highlighted as complimentary solutions in the United States.78

When presenting these alternatives in public — especially on social media — a noticeable amount of “fist shaking” and “pearl clutching” occurs from partisans unaware of how reliant stablecoins are on the U.S. and E.U. commercial banking systems. 9 10

For example, a number of prominent cryptocurrency promoters claim that draft legislation (such as the STABLE Act) would destroy innovation or even blockchains themselves. 11

As it stands today, non-compliance with the Bank Secrecy Act (BSA) is strictly speaking not “innovation.” It is regulatory arbitrage which can create a race to the bottom that may harm consumers.1213 Commercial bank-backed stablecoins are ‘innovative’ insomuch as they are not playing by the same explicit rules that other bank-like entities have to.

We will discuss them at length further below but currently – as measured in trading volume – the two most “popular” commercial bank-backed stablecoins are USDT (Tether) and USDC (USD Coin).14 Both claim to be collateralized by U.S. dollars held in custody at commercial banks. Together they accounted for nearly 90% of all stablecoin trading volume this past year. 15

How big is that volume?

As an aggregate, in 2020, on-chain volume alone from these stablecoins reached more than $1 trillion. That does not count the exchange-based (off-chain) transactions that also use these collateral-backed coins. And problematic for policy makers: the on-chain volume was exchanged with limited oversight or surveillance sharing, which is part of the reason why various governments are moving quickly to pass laws to deanonymize self-hosted wallets that are exchanging this parasitic “e-banknote” or “shadow deposit.”161718

For example, Tether and USDC are not being stifled through the proposed STABLE Act, rather they would be required to jump through the same hoops as anyone else providing similar financial services.19 Based on how their product is used, these issuers are arguably a form of wildcat banks (from the 19th century) or what is called a shadow bank or shadow payments today. Lots of shadows!

What is a “shadow bank”?

The term itself is just over a decade old but these entities existed prior to 2007. In general they are “non-bank financial intermediaries that provide services similar to traditional commercial banks but outside normal banking regulations.”20 Readers can imagine that this type of activity is what organizations such as the Financial Stability Board (FSB) would like to keep track of.

One member of the FSB is the Federal Reserve. The screenshot (above) is a relevant portion of their mandate and why they could – in theory – be interested in obtaining information of off-shore entities that are attempting to (anonymously) use U.S. linked e-banknotes.21

“Shadow banking” is occurring off-shore through intermediaries (e.g., coin exchanges and lending protocols) that use Tether or USDC without needing to connect to a local bank who would require some semblance of surveillance such as AML or CFT compliance.2223

Based on their external messaging, multiple centralized exchanges (CEXes) claim to operate banklessly but this is a superficial: they each maintain an umbilical cord to the U.S. dollar via USDT or USDC. 24 Similarly, decentralized lending protocols such as Compound or Aave accept commercial bank-backed stablecoins as collateral and allow rehypothecation of these same tokens (or others). 25

Putting aside new proposed legislation for the moment: stablecoin issuers (administrators) have fought feverishly to categorize themselves under a “lighter” more lenient regulatory regime (money service business) despite more stringent laws covering deposit-taking activities that are not enforced, such as 12 USC 378 (a)(2) being on the books. 2627

More precisely, in retrospect specific activities enabled by commercial banks (such as issuance of e-money) were not properly regulated. Righting this wrong that exists to day – so the argument goes – all MSBs (not just commercial bank-backed stablecoin issuers) should no longer be able to conduct unregulated shadow payments or banking activities.2829

Related to the concept of shadow banking is shadow money, and clearly stablecoins fit the bill. When he was a Governor at the Federal Reserve, Dan Tarullo gave a speech, stating:

“Shadow banking also refers to the creation of assets that are thought to be safe, short-term, and liquid, and as such, “cash equivalents” similar to insured deposits in the commercial banking system. Of course, as many financial market actors learned to their dismay, in periods of stress these assets are not the same as insured deposits.”

The classic example of shadow money is money market funds which were deemed to be “money good” pre-2008 crisis. Reforms were implemented post-crisis, such as redemption gates and floating NAVs for certain money funds, but in March 2020 the Federal Reserve still had to backstop money funds via the money market mutual fund liquidity facility (MMLF). Last month the President’s Working Group on Financial Markets released a report highlighting the need for further reforms to money market funds.

If consumers and investors think stablecoins are the same as insured deposits because they are “backed” by insured deposits at a commercial bank, they are clearly not. Does this mean that if stablecoins become big enough, the U.S. government would bail the sector out just like they have bailed out other shadow money investors? This is an open question but the answer should arguably be no. 30

While regulators have informally discussed systemically important cryptocurrencies networks and potentially overlap with PFMIs, to date there have been few discussions in long-form prose.31 Let us check back in on this topic next year.

Double the credit risk

As mentioned above, the credit risk (solvency) of commercial banks is worse than central banks.32 During the 2007-2009 financial crisis, while a number of commercial banks received direct taxpayer-funded bailouts that immediately underwent public scrutiny, the entire financial industry was effectively propped up through the coordinated actions of central banks and finance ministries around the world.

We could always argue about which policies should or should not have been implemented during that time. The Dodd-Frank Act was just one set of legislation that was passed in an attempt to prevent another, similar systemic crisis from happening again.

What does this have to do with parasitic stablecoins?

Transactional users and speculators of commercial bank-backed stablecoins are faced with at least two potential credit risks:

  • the credit risk of the stablecoin issuer
  • the credit risk of the commercial bank that the stablecoin issuer uses as a custodian
Source: FDIC

A conventional bank account exposes to the account holder to a single level of credit risk, the risk that the bank becomes bankrupt and is unable to meet its liabilities to account holders. In most developed countries and many developing countries, deposits are protected by a national deposit insurance scheme ranging between tens and hundreds of thousands of dollars.

Even if Signature Bank or Silvergate Bank have impeccable credit quality, they are not the lender of last resort. They rely on the implicit and explicit backing of the FDIC and the Federal Reserve.33

As a result, stablecoins present a double layer of credit risk. There is the risk that the issuer of the coins fails and the risk that the party holding the reserves (e.g. a bank, fails). Generally stablecoins would not benefit from the deposit insurance provided for bank accounts.34 Where the issuer invests in a more complex range of assets to act as reserves, such as debt instruments, it also exposes the stablecoin holder to the risk that assets fall in value, which can be an issue, even for relatively short-dated assets, where reserves have to be liquidated. 35

This raises a major question: who bears losses, the issuer or the holder of coins? An issue banks deal with (to a certain extent) by having to set aside regulatory capital.3637

In other words: a stable coin backed by commercial bank deposits has worse credit risk than simply having money in the bank because it would not benefit from any deposit insurance scheme.38

CBDCs

Tangentially related to the PFMIs are central bank digital currencies (CBDCs). Public discussions surrounding the regulation of stablecoins often neglects prior research conducted by central banks, industry, and academia.

For instance, several years ago, the Bank for International Settlements (BIS) published one of the most widely cited papers on the topic of CBDCs. In it, the so-called “money flower” Venn diagram illustrated how existing money could be categorized:

Source: BIS

As we can see, the current crop of stablecoins (such as USDC) and cryptocurrencies (such as Bitcoin) are clearly in different categories from CBDCs.

Representatives of coin lobbying organizations, such as the Chamber of Digital Commerce, makes the common mistake of conflating the two:

Source: Twitter

Are commercial bank-backed stablecoins a central bank digital currency (CBDC)?

No. There is a lot of commentary which blends stablecoins with CBDCs but they are not the same. Unless a stablecoin is backed by reserves at the central bank or issued directly by a central bank, a stablecoin marketing itself as a CBDC is being dishonest.

Furthermore, the DC/EP initiative in China is not a CBDC. It is a liability of an intermediary that is not the People’s Bank of China.39

Source: Twitter40

Are CBDCs a stablecoin?

No, although in theory central bank reserves could be tokenized and put onto a blockchain. But that’s not what is happening today (yet).41

Any other reasons why stablecoins are lumped together with CBDCs?

Stability. Credible central banks such as the Federal Reserve, provide a reliable unit-of-account such that more than two dozen countries “dollarize” their domestic economies with it. This article will not go into the merits or demerits of issuing CBDCs or if a blockchain is needed in doing so.42

Ironically, while some vocal coin promoters have claimed a “hyperbitcoinization” event will occur soon. But the cryptocurrency ecosystem as a whole has seen the opposite take place: rapid dollarization due to the growth of commercial bank-backed stablecoins. This is the central conceit for much of the coin world today: promoters and meme artisans often claim they are about to launch off from planet Earth all while drilling ever deeper foundations into the Earth’s crust.

For example, in the second half of 2020 at least four U.S.-based cryptocurrency companies applied for deposit-taking licenses or banking charters.43 And because of how embedded these tokens have become to “DeFi” apps, portions of it have turned into centralized DeFi (CeDeFi), which is an oxymoron.44

As a result, it has made anarchic chains less resilient which will be discussed later.45

Reliance on external U-o-A

One characteristic or function of actual “money” is something called the unit-of-account (U-o-A). A unit-of-account is used to price goods and services in an economy. On a macro level, economic aggregates such as GDP are measured by a stable U-o-A, such as the USD or EUR.

Similarly, international commerce and trade is often denominated in a stable U-o-A. In this case, foreign exchange ultimately takes place somewhere along on “the edges” but the price discovery and (often) payment settlement occurs in the stable U-o-A. 46

For instance, despite doomsday predictions, the USD is becoming more dominantnot less dominant – in financial markets.

What does this have to do with cryptocurrencies and specifically stablecoins?

Source: Twitter

More precisely, the question should be: why are stablecoins so popular?

The answer is one that has been discussed many times on this site: volatility.47 Contrary to what some promoters claim, Bitcoin is not becoming less volatile over time. As JP Koning illustrated in the chart (above), bitcoin is more volatile today than it was in early 2017 when it had a ‘market cap’ of just $15 billion or in 2013, when it was worth just $1 billion.

While some early coin investors and hoarders may be okay with rampant swings in volatility, actual users (such as day traders or remitters) desire stability. As a result, more than 20 different U.S. dollar-linked stablecoins have been created to fill that need. And unsurprisingly, because the identity of on-chain activity can be obfuscated, another set of stablecoin users are criminals involved in money laundering and terrorism, as identified by the Financial Action Task Force (FATF).

For the purposes of this article “stablecoin” is a catch-all term used to describe a spectrum of coins that attempt to peg a token to exogenous (external) value.48 Typically the exogenous value is denominated in USD. In terms of trading volume, the two biggest buckets of stablecoins are:

  1. Collateral-backed tokens such as USDT (Tether), USDC, PAX, TrueUSD, and DAI49
  2. Algorithmic or synthetics such as AMPL, ESD… and the older generation of BitUSD, and Nubits

In practice, nearly all collateral-backed tokens in use today are commercial bank-backed tokens that are centrally issued by a singular entity.50 In contrast, virtually all of the algorithmic tokens are launched by anonymous teams and often use a form of rebasing or Seigniorage Shares model to arrive at a value.51

The focus of this article is on the former not the latter. Let’s dive into a few of them.

Barnacles

USD Coin (USDC) is a stablecoin issued through the Centre Foundation and backed by Circle, Coinbase, and others. This entity is registered as a MSB in the United States. USDC is an ERC20 token that can be moved around the Ethereum network however the “backend” on-and-off ramps are fully powered by U.S.-based commercial banks such as Silvergate in San Diego.52

At the time of this writing about $4.3 billion of USDC has been issued. In Q4 2020, the trading volume of USDC was usually between $335 million to $1.3 billion per day.53

Image
Wiring instructions to Silvergate

USDT is issued by Tether Ltd which is also registered as a MSB in the United States.54 Customers that want to use USDT, create an account on the Tether website and link their bank account. Then using the traditional financial system, wire cash to Tether’s partner banks. USDT has been issued onto multiple different blockchains, including Bitcoin and Ethereum. As of this writing, it is the most actively used ERC20 token.

Image

Tether Ltd and its parent company (iFinex) have been debanked multiple times. Why?

Because both are under multiple investigations from several regulators and law enforcement (such as the New York Attorney General) for lying about their collateralization levels, among other allegations.

At the time of this writing about $21.3 billion USDT has been issued. In Q4 2020, the trading volume of USDT was usually between $25 billion to $80 billion per day.55

When it was initially launched in December 2017, DAI was collateralized only with ETH and the software company that created it, Maker, is not registered as a MSB (though it could be categorized as a “shadow MSB“). About 18 months ago, DAI transitioned to accept “multi-collateral” which includes other types of coins, such as commercial bank-backed stablecoins. In addition to being listed on most major cryptocurrency exchanges, traders can also buy DAI directly via 3rd party partners (such as Wyre and MoonPay).

However, depending on the day of the week, the proportion of U.S. commercial bank-backed stablecoins can comprise more than 50% of the collateral backing DAI (which is why it was identified by authors of the STABLE Act):

The chart (below) shows the growth (measured by ‘supply’) of the most popular collateral-backed stablecoins this past year.

Assuming the self-reported numbers are correct, this illustrates an increase in USD deposits sitting in banks on behalf of stablecoin issuers.

Source: The Block

Note that at the time of this writing about $21.3 billion USDT has been issued and about $4.3 billion of USDC has been issued.

The bar chart (below) shows the daily trading volume of roughly the same collateral-backed stablecoins over the past three year:

Source: Messari

Recall from above that in Q4 2020, with a few outliers the trading volume of USDT was between $25 billion to $80 billion per day and the the trading volume of USDC was between $335 million to $1.3 billion per day.

In other words, the average daily turnover for USDT was about 2 to 4 times the amount allegedly deposited with their banking partners. This likely shows that some forms of leverage, credit creation, and rehypothecation are taking place. 5657

The line chart (below) shows the total value of tokens that are locked up (TVL) in DeFi-related projects over the past ~3 years:

Source: DeFi Pulse

As we can observe above, growth of TVL substantially increased between January 1, 2020 and January 1, 2021 by about 2,000 percent. DAI contributes to about 20 percent of these deposits.

What about Diem née Libra?

With mountains of press and marketing the past 18 months, they are finally planning to launch (soon). What Libra initially proposed in the summer of 2019 (to the chagrin of regulators and payment-related partners) was that Libra would deposit user funds in multiple custody banks (like Citi) but purposefully do it in a way such that no single regulator (such as FinCEN or OCC or the Fed) would have complete oversight.  That was shot down and the proposal evolved further the past year.

For example, it initially involved pegging to a basket of currencies (including SGD) kind of like an SDR, but without FSB or IMF oversight. This put commercial banks at risk in part because of non-existent AML controls.  Thus the entire proposal was scrapped and a new narrative created through the use of a commercial bank-backed stablecoin similar to USDC.

There are other bits and bobs that we can dive into – such as the older generation of algorithmically “stabilized” coins Nubits or BitUSD – but that’s a separate, mostly irrelevant category of faux stablecoins.

What would happen if issuers of collateral-backed stablecoins had to obtain something akin to a bank charter?58 Last month Paxos (PAX) applied for a national charter in the United States, will other issuers do the same?

While there may be rigorous surveillance at the on-and-off ramps of USDC or USDT today, the same cannot be said for on-chain activity where the “Travel Rule” is ignored or compliance with the BSA is non-existent.

If the self-reported volumes at coin exchanges is accurate, then tens of billions (measured in USD) of these stablecoins are traded each day likely in a non-compliant manner. This undersurveilled activity is part of the motivation behind a new draft rule from the U.S. Treasury department.

For perspective, according to The Block in the first 11 months of 2020 stablecoins hit some hockey stick growth:

  • Supply grew 322%
  • Transaction volume grew 316%
  • Daily active addresses grew 332%

And as mentioned in the first section above, total stablecoin on-chain volume surpassed $1 trillion during 2020.59

If payment processors are held liable for the activities (e.g., knowingly processing payments for scams) that take place on their networks, the argument goes, so should stablecoin issuers. In the past, both Tether and USDC have frozen funds and blacklisted addresses due to law enforcement orders, so at a minimum they should be held to the same standard as a payment processor (but are not).

Source: The Block

Either way, it is clear that from trading activity and total-value-locked up (TVL), that the DeFi ecosystem (and all coin worlds really), are reliant on maintaining frictionless U.S. banking access.

Is this DeFi-in-name-only (DeFi-ino)? Without the on-and-off ramps into U.S. banks and most importantly – parasitic access to a stable unit-of-account, arguably the middle (TVL) activity would be a lot less than it is today.60

If the (end) goal or ethos of the DeFi world — and broader anarchic cryptocurrency universe — is to be self-sovereign and enable self-custody and not reliant on U.S. commercial banks or the Federal Reserve, the exact opposite has occurred.61

A quick DAI diversion

It is not a full barnacle however some have previously argued that DAI could become a victim of its own success. 62

How’s that? Maker’s current governance leans heavily on identifiable humans and VCs which would be hard to quickly anonymize/decentralize. Recall that its human-led governance process modified the collateralization process, allowing new types of coins and tokens to be included.63

As a result:

  1. Often more than half its collateral are other USD stablecoins (none of which have bank charters), so if these are shut down or liquidity severely restricted, this could impact DAI stability and/or liquidity64
  2. Dependence on humans to manage governance and reliance on oracles for exogenous info; these are a single-point-of-failure.

What are some solutions for Maker (DAI), whose investors and developers are identifiable?

  1. Act like cypherpunks, “disappear,” and go fully anonymous making enforcement more difficult65
  2. Eschew the current crop of oracle architecture because it is arguably a single-point-of-failure
  3. Remove collateral whitelists, which is something prominent developers have suggested in the past

Regarding that last point, here’s an example:

Source: Twitter

Let us check back next year to see what Maker, Compound, and Aave do with their formal governance and collateralization processes.

Breaking pegs

Worth noting that USDT, USDC, and DAI have either broken their pegs with the USD or at some point dramatically drifted from their pegs. There are multiple reasons why.

For example, in April 2017, USDT dropped below $1.00 and traded at $0.91.

Why the sudden drop?

As mentioned in a previous post, a lawsuit revealed that Bitfinex sued WellsFargo because the bank had refused to process Bitfinex’s international wires. Over a span of a few months, tens of millions of USD had been wired through WellsFargo into and out of four different banks in Taiwan which Bitfinex, Tether Ltd, and other affiliated subsidiaries had bank accounts with. At some point prior to March 2017, someone on the compliance side of WellsFargo noticed this large flow of USD and for one reason or other (e.g., fell within the guidelines of a SAR?), placed a hold on the funds. In early April 2017 Bitfinex’s parent company filed a lawsuit for WellsFargo to release these funds.

WellsFargo eventually returned the USD-denominated funds but without those funds, the peg was unable to withstand sell pressure. In other words, WellsFargo was integral to Tether Ltd’s correspondent banking relationships.  About a week later Bitfinex withdrew its lawsuit but not before causing a Streisand Effect.

This was not the first time Bitfinex has been “debanked.”  Phil Potter, then-CFO of Bitfinex, gave an interview and explained that whenever Bitfinex had lost accounts in the past, they would do a number of things to get re-banked. In his words:

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

With this blasé attitude, it is any wonder they are under active investigations from the Department of Justice, the CFTC, and the NY AG.

Source: Twitter

The ethos of blockchainology is supposedly: “don’t trust, verify.” Above is a tweet from Paolo Ardoino, current CTO of Bitfinex and Tether.

Because no reputable firm will provide regular audits of Tether Ltd, we are left having to trust a non-credible actor.66 For instance, in April 2019, during its legal proceedings with the New York Attorney General, Stuart Hoegner, the general counsel for Tether Ltd admitted that USDT was not backed 1:1 as was claimed on their website. Instead it was running an undisclosed fractional reserve operation that was only uncovered due to this ongoing lawsuit.

In its filing with the court, Hoegner states:

“As of the date [April 30] I am signing this affidavit, Tether has cash and cash equivalents (short term securities) on hand totaling approximately $2.1 billion, representing approximately 74 percent of the current outstanding tethers.”

Executives at the parent company (iFinex) would not even acknowledge ownership of Tether Ltd until an exposé from The New York Times revealed it was the case due to leaks from the Paradise Papers (be sure to also read Amy Castor’s timeline).

We know historically that other intermediaries have lied or misled users (and investors) of what they do with deposits. For instance, during a series of investigations in 2017 in China, at least two major domestic cryptocurrency exchanges (Huobi and OKCoin) were found to have secretly re-invested customer deposits into other financial instruments.

This type of abuse is the reason why at a minimum regular audits from reputable, independent firms are required for financial service providers. Let us check in next year to see if Tether Ltd gives us more than tweets to audit.

Innovation theater

We briefly mentioned this topic at the beginning of the article but worth looking at this closer.

In the early 2010s, several prominent VC-backed fintech efforts insisted they needed carve-outs for what they knew were highly regulated activities.67 Some even hired lobbying organizations to push the “don’t suffocate innovation” meme which persists today in the form of “deregulated finance.”68

For instance, in 2014 the New York State Department of Financial Services (DFS) proposed a new virtual currency regulation dubbed the “BitLicense.” Prior to its enactment in 2015, the same sort of “everyone will leave the US” argument was made by its opponents. Throughout the second half of 2014, DFS held multiple public comment periods, the responses of which were made public. Among others, the EFF submission included the word “innovation” thirteen times. 69 Upon its enactment, a few coin-related companies claim to have left, some vowing never to return.

From a systemic risk standpoint, is society worse off because of the small handful of coin companies that had no intention of becoming compliant with a stricter MSB, let alone a banking license, left New York? No. Is the BitLicense perfect or flawless? No.

But contrary to views of partisans, entrepreneurs continue to seek it out as a stamp of approval: as of this writing there are 25 entities that have been approved for a BitLicense (although a couple overlap).70

Three years after its enactment, in May 2018, coin-focused media gave softball interviews to the “refugees” that left New York, notably Shapeshift and Kraken. Both are cryptocurrency exchanges and had (have?) legal and regulatory issues.

At the time Shapeshift allowed KYC’less transfers to take place. That changed in September 2018 after The Wall Street Journal did an investigation discovering that Shapeshift was being used to launder proceeds of crime such as the infamous WannaCry ransomware.

Perhaps publicly telling the world that you are not going to comply with the BitLicense was a redflag?71

Source: Twitter 72

The other prominent “departure” from New York was Kraken, another U.S.-based cryptocurrency exchange.73 The CEO publicly has written multiple articles and posts on social media for why the organization would no longer cater to New York residents. But upon closer examination, in September 2018 the New York Attorney General announced that it had evidence that Kraken was still operating in New York. While that investigation simmers in the background, a year later a lawsuit was filed by Jonathan Silverman, who had run Kraken’s OTC desk in NYC for a couple of years. He sued the exchange because they had stiffed bonus payments. It is unclear what the current status of Kraken’s business is in New York, however, a number of employees appear to reside there.74

Likewise many prominent ICO promoters made similarly grandiose statements after the SEC released its report on The DAO in 2017. That capital pooling and investments would move off-shore and the U.S. would be left behind. Regulatory arbitrage certainly did take place, with hundreds of ICOs being registered in Singapore, Taiwan, and other island nations (such as The Caymans).75 But we also saw that in practice, coin-focused developer teams continue to be hired here in United States.

Either way, as Nathan Tankus correctly pointed out:

Shadow banks have always sold themselves as providing competition to the regular banking system. And to a certain extent, they do. But its an undesirable form of competition which causes a race to the bottom.

If other nations want to put their own financial infrastructure at risk due to underaccountable shadow banking – so the argument goes – that is not a great outcome but not a terrible outcome for the U.S. banking system in terms of systemic risk.76 For example, the aim of the STABLE Act is not to globally enforce a regime: it is to prevent systemic risk in the U.S. and this can be done by strictly enforcing existing laws or enacting new laws on entities such as stablecoin issuers reliant on U.S. commercial banks.

Chernobyl-backed meme coins

This may sound repetitive, one cannot overstress systemic risk in the context of an underaccountable IOU layer, as Tankus once more explains:

The [STABLE Act] is aiming at systemic risk. leaving unlicensed stablecoins as a fringe financial product offered in other jurisdictions unlisted or on minor exchanges that can survive not being able to interact with the U.S. legal system accomplishes the goal

Recall that in the U.S., the only entities that have access (accounts) at the Central Bank are commercial banks. And we empirically know that the credit risk of commercial banks is worse than a Central Bank because there is just one type of money: reserves at the central bank.

Everything beyond coins, notes, and money equivalents is arguably a credit risk. Thus, not only should we want Narrow Banks and FedAccounts created, but from a resiliency standpoint at the very least we should require stablecoin-issuers to stop piggybacking on other commercial banks due to their modus operandi.

Miners and block makers

We have touched on this topic more than a dozen times on just this site alone. Let us look at this issue from a different angle.

Visa and other payment providers are liable for certain activities that take place on their networks, hence why they on-board certain merchants and off-board others that are deemed “higher risk” or whom have violated some law.77 Similarly all FMIs have various binding agreements (MSA, TOS, EULA, SLA), and the penalty for violating them could result in a participant being removed (e.g., Fedwire has a terms of service that is effectively passed on to the users of commercial bank wiring services). ISPs and telecoms are also regulated and permissioned and they can (and do) kick users off for violating their TOS.

Proof-of-work chains like Bitcoin intentionally did not include a ‘terms-of-service’ and by design did not include hooks into any legal agreement or, for that matter, attempt to integrate AML screening of participants.78

But this is just RICO theater: in an “even Steven” world, miners should be held to the same standard as other processors. Assuming some or just one of the frameworks mentioned at the top of this article is ratified, issuers can be held accountable for additional disputes that arise.79 What then of the block makers who process transactions that fail to comply with a specific jurisprudence?

For example, in terms of proof-of-work chains – in practice – nearly all of the mining pools for both Bitcoin and Ethereum are operated by identifiable entities. FinCEN’s 2013 guidance gave miners a carve-out based on the assumption that mining pools were neutral, but in practice they are not and do manually add (or censor) transactions.

For instance, at a public event in 2019, Roger Ver and Tone Vays (aka Anthony Vaysbrod) made a bet on stage regarding sending transactions – and importantly the associated fees – across both the Bitcoin and Bitcoin Cash blockchains. To aide Vays’ attempt to send a below-market transaction fee, Slush (a mining pool), manually included it despite the below-market fee. They were not neutral the opposite to how miners are often portrayed to regulators.

With more than 10 years of operation, the Slush mining pool is the first (and oldest) Bitcoin mining pool. (Photo: the original Slush team, self-doxxed)

During the frenzy of ICO mania, the rush to get into a “capped” raise meant that some speculators would “bribe” mining pools to guarantee that their transaction could be included in a specific block. For example, in May 2017, a principal at a Canadian-listed fund successfully paid more than $6,000 to an Ethereum mining pool so that his transaction could be included during the sale of the Basic Attention Token (BAT).

We could spend a couple of posts just walking through the subreddit /r/bitcoin in what is basically the de facto customer service forum in the event that a user accidentally sends a mining fee that is too big or small.

What these human-run chains independently highlight are some of the lessons from 2015. How can validators become BSA compliant or apply for a MSB license?80

Why would they need to?

In what became the “permissioned chain” or “enterprise chain” vendor world, startups like Symbiont and Digital Asset first looked at using Bitcoin mining pools to process transactions for regulated financial institutions (e.g., banks) but ultimately walked back for a couple of reasons:8182

  1. lack of settlement finality
  2. transaction fees or payments could be going to sanctioned entities

The discussions surrounding identifiable validators (this paper uses the term “KYM” – know your miner) – and the legal and regulatory buckets they fall under – has been an ongoing topic since at least 2013. The STABLE Act potentially fixes that loophole.83

Why hasn’t law enforcement prosecuted mining pool operators in the past?  Partly because of coin lobbying organizations have successfully pushed a one-sided agenda on behalf of their donors and rallied external support by fear mongering about criminalizing node operators.8485

This is a red herring and is not the aim of the STABLE Act; in fact its co-authors believe that would be a bad strategy. But a bigger issue has been a lack of resources.  Agencies like FinCEN have in general been underresourced and went after the lower hanging fruit (e.g., ransomware profiteers in Iran).8687 It is an open question whether they will have more resources under a new administration to look at miners.88

With the roll out of real-time transaction monitoring from many different vendors, intermediaries such as cryptocurrency exchanges and mining pools can identify and flag suspicious or illicit activity before participants can fully realize their gains.

For instance, almost four-and-a-half years ago, Bitfinex was hacked and lost 119,756 bitcoins. At the time this was worth about $65 million of actual money. Today that is around $4 billion. The hacker(s) have never been (publicly) caught. Proportionally, this would be equivalent to a large commercial bank losing $20 – $30 billion USD. There have been Congressional hearings for much less.

Image
Source: Twitter

As I have pointed in previous posts and presentations (slides 10-12), at the time 9 out-of-the-first 10 mining pools that processed the stolen Bitfinex tokens operate outside of the U.S. (specifically in China).89 If a U.S.-based financial intermediary was hacked and $4 billion in customer deposits was stolen, the fine print in the terms-of-service kicks into high gear to protect customers. Despite the billions in VC funding and headline-grabbing coin prices, similar consumer protections do not exist in the coin world.90

Even with the existence of real-time monitoring from multiple vendors, intermediaries including miners have gotten away with profiteering from processing illicit transactions that would have shook up FMIs or PSPs. Ransomware, a blight on critical public infrastructure, and the processing of its transactions are something that well-resourced prosecutors could disgorge.91

Conclusion

The motivation behind anarchic chains, such as Bitcoin and Ethereum, was about creating an alternative, sovereign economy that was independent of any nation-state. But if your alternative economy uses USD (or any other fiat-linked cryptocurrency) as its unit-of-account, it is not really an alternative economy, but a subsystem subordinate to the monetary policy and pricing system of the nation that the system is supposed to be independent of.

If the aim or ethos of anarchic cryptocurrencies is to truly reduce moral hazard (e.g. taxpayer funded bailouts of banks) and systemic risks that unfortunately occur during a financial crisis, the DeFi ecosystem has a long way to reverse the current trend.92 It is not too late and in fact, client pluralism (in Ethereum) is one way to reduce systemic risk.93

“Pegged coins” are clearly fragile because they rely on an exogenous judiciary system to resolve disputes and an exogenous banking system to maintain a unit-of-account. Much of the proposed legislation above should serve as a motivation for building a more resilient on-chain U-o-A.

Perhaps the one call to action is to encourage education around “narrow banks” which could be viewed as a ‘middle ground’ between a bank charter and a MSB.94 If you are interested in learning more on the short history of commercial bank-backed stablecoins, worth re-reading the prequel from 2018 to see what has changed.

Acknowledgements

I would like to thank the following people for their feedback: AC, RG, RS, RR, CW, MW, LR, JM, PE, FC, JG, JK, KV, DZ, AV, JW, and VB

Endnotes

  1. Regarding terminology, one reviewer noted: “By necessity, a stable coin is either subsidized or fictional. Dollars cost money to hold and transact in, so the only way a stable coin can be stable is if the sponsor takes risk on the underlying or uses it as a loss leader. The term has come to imply backing. Which not only is probably not true, it doesn’t necessarily need to be true. Have you ever tried to redeem a “stable coin”? Any stability of a “stable coin” is derived not from the assets backing the coin but by the ability to sell (not redeem) for a fixed amount. Which is of course true until it isn’t.” []
  2. One commenter explained: “In the E.U., MiCA will take a while to be implemented by member states. As a result, some member states are trying to get ahead of the E.U. itself by releasing their own related laws with the aim of attracting market participants; at least until the E.U. comes to a consensus of what it will want to do. Even if being ahead of the E.U. could have short term benefits, it is also extremely important to not deviate from E.U.-wide consensus, so part of this is identifying areas that the E.U. would obviously regulate. One approach, which has been seen in Hong Kong as well, has been a phased approach to regulating cryptocurrencies by first regulating the areas that are easier to regulate (e.g. funds and fund managers, applying existing requirements to those who want to invest in cryptocurrencies), and waiting for things to develop before trying to regulate areas that are hard to regulate (e.g. custody). There is a key difference between a directive and a regulation in the E.U. A directive has to be transposed into law by the member states, which have to update their own legal systems. And when a member state is behind in transposing, like Cyprus for AMLD5, they get put in special working groups and the E.U. can even take legal action toward them. A regulation is already a law that is automatically enforceable across member states.” []
  3. The PWG uses a broad definition: “For the purposes of this statement, “stablecoins” are the digital assets themselves. A “stablecoin arrangement” includes the stablecoin as well as infrastructure and entities involved in developing, offering, trading, administering or redeeming the stablecoin, including, but not limited to, issuers, custodians, auditors, market makers, liquidity providers, managers, wallet providers, and governance structures.” []
  4. Most industry-driven commentary thus far seems to use the term “stablecoin” as if it is a well-defined concept. As one reviewer noted: “Assuming that there is a case for regulating a non-custodial coin, if you push the analysis to try to clearly characterize the type of coin that should be regulated, there is no other way to draw the boundary other than to say: coin that’s designed to track the unit-of-account of any currency that’s considered to be money under the law in question.” []
  5. It could be argued that coin promoters are looking at engagement the wrong way: the onus is not on any government to bend to the needs of coin efforts. Governments should not necessarily be accommodating since it is not a reciprocal or equitable relationship. For example, Satoshi intentionally did not architect Bitcoin to be compliant with any surveillance regime, it has been an one-way conversation — mostly a monologue — from day 1. []
  6. Recall that in both the U.S. and E.U., access to central bank accounts are restricted to commercial banks and handful of non-banks. Rather than create narrow banks themselves or seek central bank access, stablecoin issuers are arguably de-stabilizing the highly concentrated U.S. banking system by building underaccountable shadow banks on top of systemically important financial institutions (SIFIs). If an aim for “DeFi” is protecting consumers and investors, concentrating more activity onto SIFIs is not the way to go. []
  7. One reviewer who previously worked at a central bank noted: “We need to understand narrow banks and think through what they would look like. Even I have skipped this because ‘The Federal Reserve won’t approve them so why bother.'” []
  8. In his November 2020 speech, Andy Haldane, chief economist at the Bank of England, said: “On financial stability, a widely-used digital currency would change the topology of banking in a potentially profound way. It could result in the emergence of something closer to narrow banking, with safe payments-based activities to some extent segregated from banks’ riskier credit-provision activities. In other words, the traditional model of banking would be disrupted.” []
  9. Ironically by vocally defending Tether or USDC, partisans that do not like the Federal Reserve or JP Morgan are actually defending the very entities they claim to dislike, because commercial bank-backed stablecoins are just tokenized deposits sitting in a bank. And each of those banks rely on dollar-clearing services provided by the New York Federal Reserve. In other words, the aspiration of “anarcho-capitalism” is in direct conflict with how all settlement, clearing, and payment FMIs operate today; to use a stablecoin necessarily involves needing an exogenous U-o-A maintained by the Fed. []
  10. Quizzically, the “moral hazard” issue – that taxpayers are once more on the line to bailout commercial banks – has been glossed over by many DeFi and CeDeFi proponents. Again, the benefits of commercial bank-backed stablecoins largely accrue to issuers, traders, and speculators. These are privatized gains. Unless issuers move to a different banking model, they are ultimately relying on socialized losses by taxpayers via FDIC. []
  11. Worth pointing out that the article above is about specific groups of people, not technology. Several years ago Steve Waldman authored the memorable “soylent blockchain” presentation. It is germane because chains – in practice – are (often) run by identifiable humans. []
  12. One reviewer commented: “There probably needs to be a new regulatory framework, such as a narrow bank or something enabled by the STABLE Act because stablecoin issuers do not fit well in existing models. In the U.S., issuers are stuck between obtaining a bank charter versus an MSB so the current framework might accidentally muzzle innovation. If stablecoins grow to a size where meaningful risk – shadow banking, systemic risk, reduced consumer protection – are visible then how to achieve regulatory outcomes without stifling innovation? On the one hand you have the argument ‘if it looks or talks like a bank it should be regulated as one’ and on the other extreme you have ‘if it is involves a blockchain it shouldn’t be regulated.’ Both those polar extremes are wrong. Blockchain advocacy is often full of hyperbole where the centralized implementation doesn’t really follow the decentralization thesis. On the other hand, the financial industry’s default position often is: technology companies that do what we do should be as heavily regulated we are. And then financial institutions use this to curb innovation and secure their moat. The question is: how to have an enlightened discussion without interference from lobbyists in the VC-backed tech world versus the banking industry? There is probably a middle ground approach that does not result in us having to take sides. Narrow banks are one approach although it also could become political.” []
  13. One area that cryptocurrency promoters often claim “innovation” is taking place is in the cross-border or remittance arena. Yet little more than anecdotes are provided to back up that narrative. For a detailed explanation for why this narrative is probably false, see: Does Bitcoin/Blockchain make sense for international money transfers? One reviewer commented: “This is not to dismiss the very real demand for banking services in underserved markets.  The majority of companies around the world are SMEs and they provide the majority of global jobs, yet in many cases they have historically had trouble accessing banking services.  This dovetails into “open banking” – access to APIs and bank data – which is a different approach from what the cryptocurrency-focused narrative often seeks to market.” Another reviewer explained: “The argument that stablecoins are not inherently as stable because they depend on the underlying creditworthiness of the backing institution is hard to argue against. At first glance, the current generation of stablecoins allow value to reach areas of new economic interest – inclusion – that traditional banks seem to ignore, yet this is likely accomplished by eschewing strict KYC gathering, AML, and CFT compliance that banks are required to conduct.” []
  14. This article does not explore projects like USC or JPM Coin, the latter of which is ultimately backed by the balance sheet of the bank itself. []
  15. Generally speaking, most stablecoins are issued as USD. As one commenter noted: “Recently a subsidiary of GMO, a Japanese IT giant, was authorized to issue a USD and a JPY stablecoin under New York State regulations. I think we’ll see much more of these cross-border combinations. And I don’t see regulators in New York State bowing to an emerging market central bank that doesn’t want to see its currency being wrapped into a stablecoin.” []
  16. The (intentional) lack of on-chain surveillance is one of the reasons why a Bitcoin ETF has not been approved by the SEC. For instance, see Comments on the COIN ETF (SR-BatsBZX-2016-30). []
  17. One reviewer noted: “Instead of saying ‘e-cash’ I would say ‘e-banknotes’ or ‘shadow deposits’. I think ‘cash’ has specific properties that most of these blockchain/account-based payments systems don’t have. It is too generous to call them cash and for the banking laws, it is the deposit-equivalent that’s the real issue.” []
  18. Another reviewer commented: “In one scenario you effectively end up with a regulatory regime where any stablecoin issuer has to whitelist (or blacklist) the supported chains and then only custodial wallets or KYC’ed wallets can hold coin. An alternative is having to monitor activity and while this can become “theater,” compliance is still robust and the team can point to “we are doing something” that can be tweaked and tightened up. Monitoring obligations may be the route otherwise you end up having to authenticate every address as a stringent requirement. Mandatory KYC’ed addresses could make certain “digital cash” impossible to use.” []
  19. The terms within the STABLE Act also provide latitude for U.S. regulators to create ‘narrow bank’-like structures for these types of issuers. []
  20. For more discussion on defining “shadow banking” see Towards a theory of shadow money by Daniela Gabor and Jakob Vestergaard. []
  21. The Board of Governors of the Federal Reserve oversees two FMUs in the United States: CLS and CHIPS. CLS was launched about 20 years ago in part to reduce Herstatt Risk. In all cases, users of FMIs and FMUs have large MSAs to agree to. []
  22. The term “Tether” itself connotes a purposeful tie to actual money. And like the term “smart contracts,” stablecoins are neither stable and nor coins. Just a risk disguised as a rational ‘crypto safe haven.’ []
  23. One reviewer commented: “‘1-1 fiat-backed at the Central Bank’ stablecoins are close to narrow banks but far from full license banks. Lending is the risky part of the license. The Ant Group IPO debacle is in part around this distinction. We need to think through what a “just lending” bank looks like.” []
  24. Some of these exchanges allow users to trade a variety of other financial instruments and even add leverage. []
  25. Promoters often claim that these protocols are just tools that help the unbanked but that is another way of saying the ends justify the means. []
  26. A detailed explanation for how and why the MSB regime has been improperly used for years can be found in: Comment Letter – Office of the Comptroller of the Currency: Warning of the Dangers Posed by the Shadow Payment System and Shadow Digital Money by Dan Awrey, Lev Menand, and James McAndrews. []
  27. The observation around illicit deposit-taking is not new, I even wrote about it more than five years ago. []
  28. One reviewer noted: “The best argument stablecoin issuers have is “Paypal got to do it, why cant we?” the response to which is: Paypal shouldn’t have been allowed to do it, and we certainly shouldn’t repeat this mistake now when we have a real chance to fix up all of this mess.” []
  29. Another reviewer noted: “For stablecoin issuers this ‘fix’ could become a slippery slope resulting in a bifurcation of blacklisted versus white listed addresses (or coins).  Today physical cash transactions are not KYC’ed but intermediaries have KYC obligations for a reason: because they are an intermediary engaged in regulated activities (e.g., holding client deposits).  One of the innovations with cryptocurrencies was getting rid of account-based money but creating white and blacklisted addresses brings account-based money back in so if that happens why bother using it versus PayPal?” []
  30. State intervention already occurs via taxpayer subsidies to proof-of-work miners removing a raison d’être for proof-of-work mining. []
  31. One of the earliest discussions on this topic comes from an Australian attorney: Australian update: PFMIs on Crypto Exchanges []
  32. We know empirically that the credit risk of commercial banks is not zero, hence why the supervisory departments at central banks regularly perform not just audits, but stress tests to see how financial institutions would weather systemic events. []
  33. It is quite common to hear professional coin traders claim that a governmental organization like FinCEN or SEC would never shut down an entity like Tether because the knock-on effect would be devastating… that Tether was “too important to fail.” Concentration of risk this early in the game is not a good thing. []
  34. The FDIC has a history of stepping in and protecting uninsured deposits as well. Do stablecoin issuers believe this is an implicit guarantee for future crises? []
  35. Office of the Comptroller of the Currency’s guidance from October permits national banks to hold fiat stablecoin reserves. This supports the argument that these “projects” are inextricably linked sovereign currencies. And while it is likely that Acting Commissioner Brooks is replaced under the upcoming Biden administration, changing that guidance may not happen. While it can be rescinded it is probably not a high priority and it is clear that some banks were already holding stablecoin reserves and the guidance just gave them more cover. A major caveat comes in its footnote #5 regarding a 1:1 ratio for collateralization that we know, for example, Tether Ltd has lied about before. []
  36. As noted in the Appendix: “Other relevant issues to maintaining the stability, or even basic credibility of a stablecoin relate to legal and operational issues.  If the issuer of a stablecoin fails, the assets ideally should be in a legal structure that is “bankruptcy remote” i.e. the holders of the coins can claim the reserves in preference to other creditors of the issuer. The bankruptcy remoteness of the Libra foundation, or even the general recourse Libra holders would have to the reserves of the Libra foundation are currently unclear. For the stablecoins used in cryptocurrency trading such as Tether and the Gemini Dollar there are varying degrees of bankruptcy remoteness. JPM Coin (or almost any commercial bank-issued stablecoin) is supported by the overall balance sheet of the bank. Holders of JPM Coins would most likely be treated like any other bank account holder.” []
  37. Another reviewer commented: “The argument for exchanges and stablecoins to have direct Fed access to my mind is about protecting retail investors. Exchanges and stablecoin issuers encourage retail investors to make fiat deposits. These deposits are uninsured and there is no guarantee that the investor will ever get the money back. Tether specifically says in its legal documentation that it doesn’t guarantee to redeem USDT in actual dollars. Retail deposits can be lent to margin traders with or without the knowledge of the depositor, and they can also be leveraged up and traded by exchanges themselves, since exchanges seem to have no shame whatsoever about commingling funds. Fees can also be high, and naïve retail investors can be vulnerable to hacking if they leave their coins in hot wallets, as I suspect many do. This whole area desperately needs the sort of consumer protection that banks are forced to provide to their depositors. To my mind exchanges and stablecoin issuers should not be allowed to take retail fiat deposits at all unless they are licensed depository institutions, which would give them access to Fed liquidity. And retail fiat deposits on crypto exchanges should have FDIC insurance.” []
  38. A third systemic-like risk that a users faces is if and when a blockchain partitions and forks. Each issuer has a different view on handle these. For instance, according to the USDC User Agreement: “In the event of a fork of USDC, Circle shall, in its sole discretion, determine which fork of USDC it will support, if any.” []
  39. For more information on the DC/EP, be sure to read: Understanding China’s Central Bank Digital Currency by Zhou Xiaochuan []
  40. Note that Raphael Auer from the BIS wrote in response: “Interesting but that’s not what we know about the project.” Even if it turns out that the highly esteemed ex-PBoC source was wrong, the tweet still confirms that several things we call CBDCs are not direct claims on the Central Bank. And if they are not, maybe we should just call them e-money or similar terms for new forms of commercial bank money. []
  41. Projects like USC from Fnality are attempting to tokenize reserves at the central bank. While formal approvals have not been made, there is a possibility that non-banks are provided a pathway to opening an account at the central bank. For example, in July 2017, the Bank of England announced that it would allow direct access to RTGS accounts to non-bank payment service providers; this was followed up with a detailed information pack in December 2019. []
  42. What are the criteria that a CBDC must have? The BIS recently published key criteria in: Central bank digital currencies: foundational principles and core features. For a critical look at CBDCs, see “Central bank digital currency – nine key questions answered” by Martin Walker []
  43. In fact, because there is no circular-flow-of-income, proof-of-work miners must liquidate a portion of their earnings to pay utility companies and taxes in what is effectively a stable foreign currency. See Why Bitcoin Needs Fiat (And This Won’t Change in 2018) []
  44. There are several parallels between CeDeFi and permissioned-on-permissionless chains. For instance, introducing regulated intermediaries that collect KYC removes the raison d’etre for proof-of-work (as P-o-W was used to make Sybil attacks costly). []
  45. From a technical perspective, if these anarchic systems were fully resilient and sufficiently decentralized, it should not matter what laws are passed or enforced. Why? Because the assumption in 2008 and 2009 was that these proof-of-work networks would be operating in an adversarial environment. Currently the end-points (on-and-off ramps) act as weak, fragile links that can be compromised. As one reviewer quipped: “Based on the outcry on social media, cypherpunks seems to have gotten soft and forgot why proof-of-work is used.” []
  46. Nominalism‘ and why it is important to legally enforceable contracts and debt is a tangential point to this. As is nemo dat. []
  47. Even as market structure improves (i.e. new hedging products, clearing, ability to move in and out of positions cross markets), bitcoins volatility relative to actual money, persists. See: Bitcoin is not the New Gold – A Comparison of Volatility, Correlation, and Portfolio Performance by Tony Kleina, Hien Pham Thuc, and Thomas Walthe; and Bitcoin Remains Vastly More Volatile Than Traditional Currencies by Max Gulker []
  48. Some analysts and lawyers refer to a stablecoin as a “pegged coin.” []
  49. Note: TrueUSD (TUSD) was operating for an extended period without registering as a MSB. As of this writing, TrueCoin LLC (a subsidiary of TrustLabs) is now registered with FinCEN. []
  50. One reviewer commented: “Any system that involves trusting some central actor (a bank, an issuer) is not embracing the core element to cryptocurrency innovation, and is mostly just a way of using money over the internet. Since stablecoins (or coins issued by tokenized deposits at banks) fall into that category, I don’t think they’re fundamentally different from the banking I can already do today. I know some people disagree—they think the openness of the ledger still means something important—but I tend to think that’s not that big a deal if you have to rely on centralized actors again.” []
  51. Several of the “rebasing” tokens seem to be replicating the ‘Hayek Money‘ proposal from 2014. Whereas a number of the Seigniorage Shares projects frequently cite a paper authored by Robert Sams. Note: since rebase and Seigniorage Shares tokens do not custody any commercial bank-backed stablecoins, they may not be directly impacted by some of the proposed legislation. []
  52. Silvergate’s total cryptocurrency-related USD balances were up $500 million (39% QOQ) as of Q3 2020. Note: the Silvergate Exchange Network (SEN) is administered and operated by a single entity and is not a distributed ledger (blockchain). []
  53. There were several spikes for USDC beyond that amount, including one $24.1 billion spike on January 3, 2021. []
  54. Tether Ltd is incorporated in Hong Kong and registered with FinCEN, but in searching the Wyoming’s banking regulator, Tether Ltd is currently not listed. To be registered as a U.S.-based MSB, typically Tether Ltd would have to have a license with one of the state banking departments. What this means is: Tether Ltd is a foreign business that has chosen to register with FinCEN but Wyoming does not require MSBs that deal in cryptocurrency to get a state license. So Tether Ltd is operating in Wyoming as a transmitter, but does not have a license. That does not mean that the foreign jurisdiction where they reside regulates them. Many jurisdictions lack any sort of MSB framework. For instance, Canada does not have licenses for MSBs. So a Canadian business that transmits money does not operate by a separate set of rules from any other business, unlike in the U.S. where the state banking departments put limits on what sorts of assets MSBs and transmitters can hold. []
  55. There were several spikes for USDT beyond that amount, including one $211.3 billion spike on January 4, 2021. []
  56. There is leverage in the traditional foreign exchange marketplace too. Statista has a relevant chart showing average daily turnover in the global FX market. []
  57. One reviewer commented: “Credit is a huge part of the current monetary system.  We would be wrong to ignore it when we talk about stablecoins, which are interconnected with the financial system.  Stablecoin promoters who intend to disrupt this system often don’t understand the very system they are disrupting.  For example, some issuers wouldn’t be able to answer how their stablecoins would account for potential inflation or deflation, how supply and demand for these coins would be stabilized, or what happens during a crisis.  This also ties back to an understanding of interest rates, which is so often lacking among stablecoin disrupters and is an integral part of the current system. []
  58. Note: one of the common misconceptions of the STABLE Act is that stablecoin issuers would necessarily have to get a bank charter but the language of the actual bill provides lots of flexibility to regulators. []
  59. We do not want to conflate velocity with TVL or rehypothecation either. Without the ability to see an exchanges books, the leverage facilitated by on-chain lending protocols is likely a magnitude order less than the leverage provided by off-chain exchanges. []
  60. One reviewer commented: “The rapid growth in DeFi is directly correlated with the developments of the current generation of stablecoins, and this has been used to justify DeFi’s current value proposition. As a result, I do not see that as a sustainable way to create real value because of the dependency on these types of stablecoins. Programmable money and programmable assets is where the real innovation is and ideally neither should be reliant on pegged coins.” []
  61. In other words: if large portions of “DeFi” applications rely on USDC or USDT, arguably this is incompatible with cypherpunkism or the decentralize-all-the-things meme. []
  62. One reviewer noted that: “Cryptocurrency, like Bitcoin, was supposed to be sui generis. But if you peg or wrap to a fiat currency you are going to fall into regulatory problems.  Even if DAI itself was just cryptocollateral they have a human-run governance mechanism and it is pegged to the dollar so it could fall under Securities law or Exchange regulations.  If DAI remained entirely crypto, would be less problematic.” []
  63. Maker maintains a public forum in which new types of collateral are proposed and voted on. []
  64. In contrast, RAI only uses ETH as collateral and Seigniorage Shares is re-based solely on endogenous info. It is arguably hard to do but using endogenous data from the chain itself to rebase the coin value leads to a more resilient app and system (e.g. hard to switch off). []
  65. Coin promoters – some of whom call themselves as cypherpunks – can ignore whatever regulations they want but that doesn’t prevent regulators and law enforcement from attempting to regulate and enforce activities in their remit.  Over time the modus operandi of some coin promoters has shifted away from an endogenous engineering effort: ‘we have built an anti-fragile sovereign network and exited, so who cares what the government does.’  It has shifted towards an exogenous model, wherein coin promoters ask their followers to write to policy makers and donate to coin lobbyists because a popular “dApp” relies on something that the government regulates. []
  66. Friedman LLP was the most recent auditor and they publicly walked away from Tether Ltd in 2018. See also research from professor John Griffin. []
  67. One germane social media comment: “Stablecoins are IOUs with collateral in state-issued money. You can not expect non-intervention from State if you peg your asset to money issued from State. Stablecoins are Statecoins.”  Another said: “If your coin is pegged to the USD, I don’t think you’re sticking it to The Man quite as much as you think you are.” []
  68. Felix Salmon arguably had the most adroit take on the pushback against the STABLE Act. []
  69. Another example: during the summer of 2014, rumors circulated that the BitLicense was about to be enacted (it wasn’t until the following year). During one of these periods, billionaire Tim Draper and his son, Adam, hosted a public meetup at their “university” in San Mateo. Multiple speakers repeated the same erroneous claims that the license would stymie “innovation.” Another memorable exchange was an reddit AMA with Ben Lawsky (then-Superintendent of Financial Services and architect of the BitLicense) in which the word “innovation” was flung around a lot as well. []
  70. Executives from overseas cryptocurrency exchanges used to tell investors and potential investors that they had submitted paperwork to receive a BitLicense. This “impressive feat” was meant to show how “legit” the exchange was. One story involved Bobby Lee, then the CEO of BTC China, telling potential investors in the U.S. that BTC China had filed the paperwork with DFS. But what was left unsaid was that the application was mostly left blank and may actually have never been sent at all. []
  71. Following the WSJ exposé, ShapeShift implemented identification checks for all trading activity. []
  72. Note: I did say something similar to that on stage at the American Banker event. It was a panel that included Barry Silbert, who coincidentally was helping ShapeShift fundraise the next round at that time. It was the only panel whose video was not published online because not all of the panelists would give A/V permission to do so. The funding round was announced two months later. []
  73. Payward Inc is d/b/a Kraken. It is registered with FinCEN as a MSB and has licenses in more than 50 territories and states. Strangely, Kraken’s Chief Legal Officer – Marco Santori – recently said Kraken is not a MSB: “Kraken is not a money transmitter. We haven’t sought licenses in the U.S. This is an alternative path to that, speaking purely from the regulatory perspective. The SPDI charter will help us to satisfy those rules as we seek to bring more and more of the payments flow in-house.” Technically speaking, a MTL is a subset of the MSB but unclear what that means in the context of Kraken or Tether Ltd. []
  74. One of Kraken’s vocal investors, Caitlin Long, lobbied on their behalf in Wyoming and helped them gain approval for an SPDI. It will be interesting to see which bank(s) in New York handle the correspondence wiring between the two states. []
  75. Dozens, perhaps a couple hundred, ICOs have registered in Singapore. The accommodative stance from MAS stems in part due to political influence from senior leaders, some of whom are believed to own ICO tokens. []
  76. One reviewer commented: “It is probably too extreme to requires cryptocurrency exchanges and stablecoin issuers to become licensed banks. I think exchanges and stablecoin issuers that don’t deal with retail investors should be allowed to do what they like on the understanding that if they get into trouble, they will have no help whatsoever from the Fed Reserve or the U.S. government. But exchanges and stablecoin issuers that take retail deposits must be licensed and subject to banking regulation, and there may also need to be legislation to enforce structural separation of retail deposit-taking from crypto trading – something like a modern Glass-Steagall Act.” []
  77. Technically speaking Visa is a card association that provides products to intermediaries, including access to VisaNet. Visa directly competes with China UnionPay and Mastercard. They operate tangentially to Square or Stripe who operate payment gateways on behalf of merchants. In his debate hosted by The Block, Jeremy Allaire conflated USDC issuance with activity on PayPal and Venmo.  This is apples-to-oranges because USDC issuance and redemption happens at the very edge.  And unlike PayPal and Venmo (who can continuously surveil internal accounts), USDC via Centre cannot on Ethereum.  In fact, PayPal will not allow cryptocurrency-related transfers because the organization would be unable to comply with the “Travel Rule” or other FinCEN reporting requirements which by definition would mean USDC operates under a less strict framework relative to commercial banks.  Note: other brokers such as Robinhood, Sofi, and Webull also do not allow users to transfer coins. []
  78. There is some irony in how proof-of-work (P-o-W) chains have evolved. Initially P-o-W was used because Satoshi wanted to make Sybil attacks expensive in an adversarial environment with unknown participants including governments. Over time, as the dependency on U.S. and E.U. banks has grown, many promoters are now stating that governments better not (properly) regulate commercial bank backed-tokens despite some of these same promoters linking their KYC’ed wallets to other intermediaries. In theory, anarchic chains maneuver around The Man, by decentralizing and pseudonymizing the set of parties responsible for processing transactions. But in practice, most activity — more than 80% — still takes place between trusted intermediaries. []
  79. From a systemic standpoint holding specific parties (issuers) responsible for activities they permitted (or were involved in) is a positive development. Why? Because, like banks or even payment processors, stablecoin issuers would have to monitor malignant behavior more closely than it does today. []
  80. For perspective, at the state level there are MSB and/or MTO licenses that the entity such as a cryptocurrency exchange has to apply for. A couple of states don’t license this activity, hence why a few large cryptocurrency exchanges have 47 or 48 licenses. At the federal level the entity also registers with FinCEN (and then complies with the BSA). []
  81. I wrote the most widely cited paper on “permissioned chains,” the creation of which was spurred by the inability of P-o-W chains to provide settlement finality or meet other requirements of the PFMIs. []
  82. One of the problems with “enterprise”-focused blockchains or distributed ledgers is that they often introduce a single-point-of-trust (SPOT) which reduces their resiliency and makes them a poor candidate as an FMI. See also: “B-words,” “Evolving Language: Decentralized Financial Market Infrastructure,” and “Decentralized Financial Market Infrastructures” (forthcoming). []
  83. Bears mentioning that if any anarchic chain has to rely on exogenous legal or financial support then it is not sovereign or anarchic. For example, each day somewhere there are multiple courts around the world in which aggrieved parties sue one another because of activities involving cryptocurrencies. While some of the outcomes remain as judicial precedent, others could become codified as statutes by legislatures. In either case, the disputes are not being handled on-chain. This off-chain dispute handling is another example of the “parasitic” reliance that anarchic chains continue to have on exogenous legal systems. []
  84. For example, Coin Center published an article scaremongering readers into thinking the STABLE Act would – among other allegations – criminalize node operators.  Vocal maximalists did the same thing.  Not only are these claims unfounded but neither of these groups are focused on consumer or taxpayer protections. Commercial entities involved in money transmission, payment services, and/or using financial market infrastructure have to comply with a sundry of requirements in each jurisdiction they operate in.  Irrespective of how mining nodes or non-mining nodes are categorized in the U.S. (or elsewhere), a “sufficiently decentralized” network should be resilient in an adversarial environment, including one with State-sponsored law enforcement snooping around.  No one but faux “crypto lawyers” are talking about outlawing anonymous ledgers or chains. In other words, non-neutral critics are dwelling on remote edge cases that are outside the Overton Window. No law enforcement is going to go door to door searching for a Raspberry Pi node. []
  85. One reviewer explained: “At both the state and federal level, governmental bodies in the U.S. have done a lot of heavy lifting and diligence to understand the cryptoasset and blockchain space. They have given it space to grow and develop, much more so than other innovations like drone deliveries which are just now being approved. For instance, the SEC created FinHub in 2018 which has its own permanent office; and in 2020 the SEC released a safe harbor proposal for special purpose broker dealers for custody of digital assets. If U.S. regulators wanted to kill the cryptoasset space, they could always go to the extent of cutting the cables, and destroying the servers, or using physical force and throwing everyone involved in jail, but what they have done was the opposite. It may have taken a couple of years to build capabilities and get it right, but they have devoted real resources and staff to make sure they understand what cryptoassets and blockchains are.” []
  86. According to a recent article from Politico, the Office of Terrorism and Financial Intelligence is one of the few areas at Treasury under Secretary Mnuchin that has seen a resource bump. This trend could continue under the Biden administration as the recently passed NDAA included provisions (Section 6102) to enhance FinCEN’s capabilities and widen the definition of what a financial institution and money service transmitter are to broadly include other entities such as all virtual asset service providers (VASPs). []
  87. A savvy prosecutor could probably make an easier case for why a mining pool / block maker is legally liable for say, knowingly processing ransomware payments because they are the “issuers” of coins. Whereas it may be harder to build a case against a vanilla non-mining node operator who merely performs non-administrative tasks. []
  88. Run-of-the-mill “validating” nodes are not equivalent to actual miners who process transactions and build blocks.  Without re-earthing the multitudinal debates around UASF / SegWit2x circa 2016-2017, mining pools are objectively in a different league. Non-mining nodes are often (but not always) overstated in importance on anarchic chains. With Deadcoins.com as evidence, proof-of-work chains live and die by miner participation. []
  89. Of the ten pools, the sole exception was Bitfury, who uses its political connections in the Republic of Georgia to receive taxpayer subsidies for its massive mining operations. About 10% of the energy production in the Republic goes towards powering Bitfury’s mining rigs. []
  90. This is not an idle thought experiment. In 2016, fraudulent wiring instructions from a compromised SWIFT account of the Central Bank of Bangladesh resulted in multi-year, multi-national investigation. Whereas the hackers attempted to transfer $1 billion to the Philippines, because of the financial controls and fraud detection framework at the New York Federal Reserve (which clears these types of transactions), only 10% of the total funds were transferred and of the stolen funds about 15% has been recovered. In contrast, throughout 2020, the hacker(s) in control of the stolen Bitfinex coins continued to peel off portions of the heist into unknown wallets. The restitution to the Bitfinex victims is itself worth looking at, as it involved the exchange self-issuing two different IOUs (BFX and RRT). Further Balkanization via more tokens by intermediaries is not the answer to hacking, oversight and accountability are. []
  91. Ransomware is a multi-billion dollar industry that has grown to new heights because of liquid cryptocurrencies used in payments from victims. For more, see: Ban All Ransomware Payments, in Bitcoin or Otherwise from JP Koning. []
  92. One reviewer commented: “In theory, all prudential regulations should be proportional to the risks. In addition to payment versus lending, most stablecoins are likely too small to be categorized as “systemic.” This is not an argument to not regulate them, it is one to phase in levels of regulation on stablecoins based on design and scale. Nobody wants to hear this, but here ETFs are probably a better parallel than banks. Maybe a way out is opening access to Central Bank accounts to stablecoin issuers (not individuals directly) and regulating other types of stablecoins as securities.” []
  93. In the Ethereum world there is clear separation between a reference design (Yellow Paper) and client implementation. In practice, there are multiple independent teams working on different client implementations written in different coding languages. In the event one team disappears or one implementation has a bug and crashes, the network can continue to work. Pluralism creates resiliency. In contrast Bitcoin is developed in the opposite manner: the Bitcoin Core implementation used by block makers is also the reference design. Confusingly, a group called “Bitcoin Core” acts as a gatekeeper to the Bitcoin Improvement Proposal (BIPs) and have used their position to lobby exchanges and miners to prevent or stifle certain alternative client implementations and/or BIPs from being adopted (such as SegWit2x). See: Who are the administrators of blockchains? []
  94. See The Broad Consequences of Narrow Banking by Matheus Grasselli and Alexander Lipton. []

Have PoW blockchains become less resource intensive?

More than a couple of people have asked for an update to a popular post published 14 months ago.

What has changed?

Before we begin, a quick reminder: the basic security model behind proof-of-work (PoW) blockchains is to make it economically costly to successfully rewrite the chain’s history. Finite resources, whether it is in the form of electricity or semiconductors, have to be consumed.

Therefore, a PoW chain such as Bitcoin, cannot simultaneously be secure and inexpensive to operate. Because if it was inexpensive to operate it would also be inexpensive to successfully attack.

proof of work, ethereum, mining, blockchain
Source: Crypviz

Bitcoin

For Bitcoin, Bitmain announced its S17e system which can churn out 64TH/s.  Each machine consumes ~2880 watts at the wall.  The first of these units are scheduled to be shipped to customers in November (however other less powerful variants shipped during the summer).

The current Bitcoin hashrate has been oscillating around 100 million TH/s the past few weeks.  

[Source: Blockchain.info]

If the entire network was comprised of the unreleased S17e-based machines, there would be around 1.56 million of them. In a given year these would gulp down about 39.4 billion kWh. But we know that is not the case yet. Thus, this will serve as our lower bound.

Bitmain is also shipping several other newly released systems, including the T17e.  Like its cousin above, the T17e also consumes about ~2880 at the wall. But it is not as efficient per hash: creating only 53 TH/s with the same amount of electricity.  

Why manufacture and sell two (or more) different machines that draw roughly the same amount of power?  

Cost.  the T17e costs $1665 and the S17e is $2483. The target market for the T17e is supposedly for miners who have low or no electricity costs.

How many T17e’s would it take to generate the 100 million TH/s network hashrate?  About 1.88 million; or an additional 300,000 more machines than the S17e.

A quick pause. these types of bulk purchases are not idle speculation. In the middle of last summer, during a two-week period of time, the equivalent of 100,000 mining machines was added to the Bitcoin network (likely early variants of the S17). This is a reversal from last November, wherein the equivalent of ~1.3 million S9s were taken offline during one month.

Again, we know that in practice that there are many more less efficient miners still online.  But crunching the numbers, 1.88 million machines each pulling in 2.88 kWh over one entire year results in…  ~47.6 billion kWh annually.

Another Bitmain machine purchasable today is the new T17 that generates 40 TH/s, drawing about 2200 watts at the wall.  It would take about 2.5 million of these to generate the Bitcoin hashrate all while consuming…  ~48.2 billion kWh per year.

To be thorough, Bitmain released the S9 SE in July which generates 16 TH/s, drawing 1280 watts.  It’s unclear how many of these have been sold but if the entire network was comprised of these: 6.25 million would need to be used.  And they would collectively guzzle ~70 billion kWh. This would be a plausible upper bound.

For comparison, if Bitcoin (T17) were its own country it would at minimum consume roughly the same amount of electricity as Romania or Algeria. If the network were comprised of just S9 SE’s, that’d be about the energy footprint of Austria. In either case, very little is value is produced in return… aside from memes and lots of social media posts. And no, despite historical revisionism by maximalists, “hodling” is not what Bitcoin was originally designed for.

As mentioned in the previous post: no other payment system on earth uses the same amount of electricity, let alone aggregate number of machines, as a PoW coin network. That is a dubious distinction.  

In looking at my previous post you will see a similar figure.  In August 2018, using the (older) S9 machine (~13 TH/s) as a baseline, the Bitcoin network consumed about ~50.5 billion kWh / year.1 Some of these types of machines (like the S9 SE) are still on.

Thus whenever you hear a PoW promoter claim that:  

  • Bitcoin doesn’t use much electricity; or
  • Bitcoin’s electricity usage will naturally decline over time; or
  • Bitcoin is more efficient than traditional payment systems

You can rightly tell them all of those claims are empirically false. In fact, the only way for the resource demands of a PoW coin to decline is if there was a long decline in the coin price.

What do taxpayers – who underwrite the state-owned utility companies – get in return for subsidizing these energy guzzlers? New economic zones of growth and prosperity?

Nope.  According to Chainalysis, in a given day more than 90% of activity on the Bitcoin network is simply movement from one intermediary to another. 2 Coin trading is by far the largest category.

Image

And since most of these coin intermediaries increasingly require some form of KYC / AML compliance, the Bitcoin network has morphed into a expensive permissioned-on-permissionless network that has the drawbacks of both and the benefits of neither. There is no point in using PoW in a network in which all major participants are known: Sybils no longer exist.

A common refrain by PoW promoters is, Christmas lights and set-top boxes also consume huge amounts of energy!

First of all, that’s a whataboutism.  But it also ignores how several Bitcoin mining manufacturers have actually tried to embed chips into these wares.

For instance:

  • Bitmain has a couple of routers called the Antrouter that will mine either BTC or LTC for you.  
  • Bitfury has marketed Bitcoin mining light bulbs.

As you can imagine, a fixed unit of labor eventually becomes unprofitable once difficulty levels increase.  It’s the same fundamental problem that faced the 21.co toasters. Thus neither of these took off (the light bulb didn’t ship) even though retail users often keep both their home routers and living room lights on all day.   Historically PoW equipment becomes e-waste fast and the last thing consumers want is embedded e-waste that guzzles electricity.3

We haven’t even touched on other PoW coins such as Ethereum, Bitcoin Cash, or Monero…  but it is worth pointing out that nearly all of the money going to miners via the block reward is value leaking from the system, either to semiconductor manufacturers or state-owned utilities.

This isn’t idle speculation either, as Nvidia counted on massive consumption of its GPUs in early 2018 which didn’t materialize due to the crash in coin prices. This led to a glut of high-end GPUs in its channel partners, which hit Nvidia’s bottom line and was later reflected by a 50% decline in share prices (the same phenomenon impacted AMD too):

Source: TechSpot

Apart from a couple of small investments, the value that a couple of semiconductor manufacturers or a clique of state-owned utilities receives via mining is money that is not being invested towards developing the chain itself.    

And some of these mining manufacturers have privatized gains at the expense of taxpayers. For instance, Bitfury, used its political connections to obtain cheap land in the Republic of Georgia where it setup massive mining farms:

 “The efforts have given Georgia, with 3.7 million people, a dubious distinction. It is now an energy guzzler, with nearly 10 percent of its energy output gone into the currency endeavor.”  

In Kyrgyzstan, 45 “crypto” mining firms consumed more energy than three local regions combined:  

“[They] consumed 136 megawatts of electricity, which is more than the amount consumed by three Kyrgyzstan regions: Issyk-Kul, Talas and Naryn.”  

Uzbekistan’s Ministry of Energy has introduced a new bill that would dramatically increase the electricity price to miners who are viewed as being “very energy intensive.”

We could probably create an entire post on these types of stories too.

At least Bitcoin is “decentralized,” right?

While the farms may be geographically dispersed to areas with the cheapest electricity, the mining pools, mining manufacturers, and other infrastructure participants are a small and centralized enough group that they can fit into a hotel for regular conferences.

Source: Twitter

Time to look at other chains.

Bitcoin Cash

Because it is nearly identical to Bitcoin (albeit with a few changes such as a larger block size), we can pretty much do the same set of calculations as we already did above.

Source: BitInfoCharts

Unlike Bitcoin, Bitcoin Cash has seen a dramatic decline in hashrate since it peaked at over 5 million TH/s earlier in the summer. It is now oscillating around 2.5 million TH/s.

For Bitcoin Cash, with a Bitmain S17e system, remember it generates 64TH/s and consumes ~2880 watts at the wall. If the entire network was comprised of the unreleased S17e-based machines, there would be around 40,000 of them. In a given year these would use about 985 million kWh. This will serve as our lower bound.

Bitmain’s S9 SE generates 16 TH/s, drawing 1280 watts. It’s unclear how many of these have been sold but if the entire network was comprised of these: ~156,000 would need to be used. And they would collectively use ~1.75 billion kWh. This would be a plausible upper bound.

Not counting e-waste, that would put the energy usage of Bitcoin Cash somewhere around 150, between Benin and The Bahamas. Compared with last year (when it was around 122), this decline is largely due to the nearly 60% price decline in BCH. This once again illustrates that hashrate follows price (e.g., miners expend capital chasing seigniorage).

Ethereum

Coupled with “the thirdening” in February (in which block rewards declined from 3 to 2 ETH), and an overall decline in ETH prices, hashrate also declined over the past year:

Source: Etherscan

According to Coinwarz, the hashrate is oscillating around 200 TH/s, about 1/3 it was when the previous article was written.

A proposed ASIC from Linzhi that hasn’t been built or shipped aims to generate 1400 MH/s with an electricity consumption level of 1 kWh. As the story goes:

To put those figures in perspective, NVIDIA’s GTX TitanV 8 card is now one of the most profitable piece of equipment on the ethash algorithm, able to compute 656 MH/s at an energy consumption level of 2.1 kWh, according to mining pool f2pool’s miner profitability index.

There are a couple of other ASICs on the market including one from Innosilicon and another from Bitmain. The previous post looked at the same Innosilicon A10 on the market, so to simplify things and because the Bitmain machine is roughly just as efficient, let’s reuse it here.

The A10 generates 485 MH/s and consumes ~850 W. The Ethereum network is around 200,000,000 MH/s. That’s the equivalent of 412,371 A10 machines.

Annually these would consume about 3.1 billion kWh per year. Around 132, about as much as Senegal or Papua New Guinea.

If we used the GTX TitanV 8 card, as described in the article above, we find that 304,878 GPUs would be used. These would consume 5.6 billion kWh per year. That’d be around the same amount that Mongolia does annually.

This is one of the reasons why Ethereum is transitioning over to proof-of-stake. As Vitalik Buterin said last year:

I would personally feel very unhappy if my main contribution to the world was adding Cyprus’s worth of electricity consumption to global warming.

Will the nebulously defined “DeFi” on an actual proof-of-stake system change the usage dynamics in the future?4

Litecoin

Litecoin, better known as Bitcoin’s other testnet, has seen its hashrate decline along with its price.

Source: BitInfoCharts

For simplicity sake, let’s call it an even 300 TH/s which coincidentally it was at 14 months ago too. CoinWarz says it is also currently around that, who are we to argue with them?

As mentioned in the previous article, Bitmain’s L3+ is still around. It generates ~500 MH/s with ~800 watts. A slightly more powerful L3++ is on the market as well.

There are the equivalent of about 600,000 L3+ machines generating hashes.

As an aggregate:

  • A single L3+ will consume 19.2 kWh per day
  • 600,000 will consume 11.5 million kWh per day
  • Annually: 4.2 billion kWh per year

It would be placed around 124th, between Moldova and Cambodia.

According a distributor, the Antminer L3++ specifications:

  1. Hash Rate: 580 MH/s ±5%
  2. Power Consumption: 942W + 10% (at the wall, with APW3 ,93% efficiency, 25C ambient temp)

If only L3++’s were used, the outcome would be about the same. 5

This consumption is pretty absurd once we factor in things like how there is only a couple of active developers who basically just merge changes from Bitcoin into Litecoin.6 In other words, one of the largest PoW networks has very few users or developers, yet consumes the same amount of energy as Moldolva. How is that a socially useful innovation?

Note: an easy way to double-check our math on this specific one: the price of LTC is nearly the same today as it was 14 months ago. Ceteris paribus, miners will expend capital no higher than the coin price, to ‘win’ the seigniorage.

Monero

In terms of mining, it appears that several decisions makers (administrators?) in the Monero world really dislike ASICs. So much so that they routinely coordinate forks that include “ASIC-resistant” hashing algorithms. Stories like this are mostly just PR because we know that any PoW coin with a high enough value, will eventually become the target of an ASIC design team.7

Source: BitInfoCharts

From the chart above, you can clearly see when the forks occurred that added “ASIC-resistance.”

Compared with the previous article, the hashrate has declined by about 1/3rd to about 325 MH/s. And it is believed that most of this hashrate is generated by GPUs and CPUs.

There are lots of how-to guides for building a Monero mining rig. Rather than getting into the weeds, based on this crazy 12-card Vega build, the user was able to generate 28,100 hashes/sec and consume 1920 watts. That’s about 2341 hashes per card (more than 10% faster than the one used in the previous article).

That’s about 138,829 GPUs each sipping 160 watts. Altogether these consume 194 million kWh annually. That’s likely a lower bound for GPU mining.

If we reused the Vega 64 mentioned in the previous article, there would be about 162,500 GPUs at the current hashrate. These would consume around 228 million kWh annually.

Not surprisingly, coupled with the “ASIC-resistant” fork and a coin price decline of nearly 50%, this resulted in about 1/3 energy used from the previous year. But this is still not an upper bound because it is likely that CPUs contribute to a non-insignificant portion of the hashrate via persistent botnets and cryptojacking.

Based on the same electricity consumption chart as the others, Monero would be placed somewhere above Grenada and the Mariana Islands. Perhaps a bit higher if lots of CPUs are used. Remember, this is called CPU-cycle theft for a reason.8

Conclusion

In aggregate, based on the numbers above, these five PoW coins likely consume between 56.7 billion kWh and 81.8 billion kWh annually. That’s somewhere around Switzerland on the low end to Finland or Pakistan near the upper end. It is likely much closer to the upper bound because the calculations above all assumed little energy loss ‘at the wall’ when in fact there is often 10% or more energy loss depending on the setup.

This is a little lower than last year, where we used a similar method and found that these PoW networks may consume as much resources as The Netherlands. Why the decline? All of it is due to the large decline in coin prices over the preceding time period. Again, miners will consume resources up to the value of a block reward wherein the marginal cost to mine equals the marginal value of the coin (MC=MV).9

This did not include other PoW coins such as Dash, Ethereum Classic, or Bitcoin SV… although it is likely that based on their current coin value they each probably consume less than either Litecoin or Bitcoin Cash.

Thus to answer the original question at the beginning, the answer is no.

PoW networks still consume massive amounts of electricity and semiconductors that could otherwise have been used in other endeavors. Some of these power plants could be shut down entirely. PoW-based cryptocurrencies crowd out and bid up the prices of semiconductor components.10 Apart from a few stories designed to pull on our heartstrings, little evidence exists (yet) for PoW coins creating socially useful economic output beyond moving coins from one intermediary to another.

And because most coins are mined via single-use ASICs, they generate large amounts of e-waste which leaks value from towards a small clique of semiconductor manufacturers and (mostly) state-owned utilities, neither of whom typically contribute back to the coin ecosystem.11 Will this change in the next 14 months?

Related links

Endnotes

  1. I – and many others – have written about this before. PoW mining is a Red Queen’s race — miners are incentivized via block rewards to expend additional capital on mining, but the total reward available to miners is fixed. Thus while chip efficiency may increase each generation, miners as a whole increase capital outlays for equipment rather than reduce. []
  2. According to The Token Analyst, nearly 7% of all mined bitcoins reside in exchanges. []
  3. Another way some have used to describe Bitcoin is an ASIC-based proof-of-stake. But really it is DPOS but not with the “D” that you may be thinking. Since mining equipment rapidly depreciates (with a typical lifespan of less than 18 months), Bitcoin arguably uses depreciating proof-of-stake. []
  4. According to both DappRadar and State of the Dapps, there has been about a marketed increase in “users” and Dapps (although they combine all Dapp platforms, not just Ethereum). []
  5. Although obviously, as in all examples above, there are loses in efficiency as the energy travels from the power plant all the way through the grid and into a home or office. []
  6. If there is only one actual developer maintaining the Litecoin codebase, how is this ‘sufficiently decentralized’ or not an administrator under FinCEN’s definition? Even the “official” foundation is basically out of funds. []
  7. Wouldn’t it be interesting if a few botnet operators or sites like The Pirate Bay were moonlighting as Monero developers, so they could directly benefit from CPU mining? []
  8. Outright theft continually takes place. For instance, a Singaporean allegedly stole $5 million worth of computing power to mine bitcoin and ether, and “for a brief period, was one of Amazon Web Services (AWS) largest consumers of data usage by volume.” []
  9. See Bitcoins: Made in China and The Marginal Cost of Cryptocurrency by Robert Sams []
  10. During the most recent bubble, DRAM prices soared in part because of demand from cryptocurrency mining. []
  11. Emin Gün Sirer has done a good job explaining this ‘leakage.’ Recommend watching his Devcon 5 presentation on Athereum. []