Book Review: “Number Go Up”

I recently finished reading the Kindle version of Number Go Up by Zeke Faux. This marks my 11th book review of cryptocurrency and blockchain-related books. See the full list here.

But… Number Go Up is marketed as a cryptocurrency book which is debatable. I would categorize it as True Crime with certain cryptocurrencies and centrally-issued pegged assets (like USDT) providing the enabling infrastructure.

It is a refreshingly witty book on a subject matter that is chronically filled with mindless conspiracy theories or Messianic price predictions.

Faux walked the tight rope, delivering a fairly nuanced and informative testament in an otherwise cacophonous market. Best of all it includes copious amounts of first-hand comments straight from the horses mouth of actual insiders, not wannabe social media influencers.

I read this back-to-back with Easy Money, by Ben McKenzie and Jacob Silverman, which was a dud in comparison. Easy Money was riddled with numerous mistakes that should have been caught when the manuscript was sent for independent fact-checking.

One quantitative example of how robust Number Go Up was, it contained 45 pages of references. In contrast, the shallow Easy Money contained a mere 8 pages of references.1 And while both books touch on some of the same topics (Tether, FTX, Celsius) and even interview some the same exact participants (SBF, Mashinsky, Pierce), Faux’s version of the events is not only richer in detail but often includes additional supporting characters… all without having to rely on an entourage.

Did I mention this was a witty book? In the margins I wrote: jhc, haha, lol, jesus, wow, burn and several variations therein about 25 times. It didn’t make the reader just laugh either. There were several times you could easily become angry, such as the face-to-face encounters that Faux had in Cambodia investigating romance-scam “pig butchering” compounds.

While the book occasionally discusses some technical concepts, it does not attempt to bog the reader down in a sundry of technical details. And when Faux did present something technical – like how a wallet works – he was in and out with the lesson in a few sentences.

If you could only read one book on the rise and fall of the most recent (virtual) coin bubble, be sure to check out Number Go Up.

With that said, despite the excellent prose and editing, I did find a few things to quibble about. But unlike the last two book reviews, there are no major show stoppers requiring a second edition to fix.

Prologue

Faux gets down to business, on p. 9 writing:

I’d like to tell you that I was the person who exposed it all, the heroic investigator who saw through one of history’s greatest frauds. But I got tricked like everyone else.

I’m not quite sure when I began following him on Twitter, but it has been at least a year. And not once during the collapse of the lending and exchange intermediaries last year did I see him do victory laps. Perhaps he did some quiet grave stomping late at night or on the weekend that I missed, but the tone of this book feels congruent with his online voice. And unlike the always-on coinerati (and anti-coiners who shadow them), the author upfront notes that he got tricked, we all did. 2

On p. 12 the author writes:

Thit is the story of the greatest financial mania the world has ever seen. It started as an investigation of a coin called Tether that served as a kind of bank for the industry.

As I pedantically questioned in other book reviews: by what measure was the 2020-2022 bubble the greatest financial mania the world has ever seen? Maybe it is, but in my adulthood the GFC seemed like at least a magnitude larger due to the existential issues of SIFIs and TBTF banks.

On p. 13 the author writes:

I pitched this book to my publisher in November 2021, near the mania’s peak, on the premise that crypto would soon collapse, and I’d chronicle the catastrophic fallout. Three months later, I was sitting with Bankman-Fried at his Bahamas office and looking at the computer screens behind his fuzzy head.

I think the author short changes himself a little here because chronologically he was already doing some sleuthing at the beginning of the year, attending Bitcoin Miami and other events.3 The timing is happenstance because not too far from his dayjob, according to Easy Money, both McKenzie and Silverman also met in a bar in New York to discuss pitching a book to a publisher at around the same time.

On p. 13 the author writes:

I told him my theory: that the coin called Tether, the supposedly safe crypto-bank that served as the backbone for a whole lot of other cryptocurrencies, could prove to be fraudulent, and how that could bring down the whole industry.

As mentioned above, I read this book immediately after completing Easy Money and in reading this particular sentence I had a small sense of déjà vu because that was their thesis too.4

Chapter 1: “I Am Freaking Nostradamus!”

On p. 15 he writes:

Don’t worry about how exactly a dog joke turns into a financial asset—even Dogecoin’s creator didn’t understand how it happened.

While Faux does provide a reference to an interview with Jackson Palmer, it bears mentioning to the readers that Dogecoin was co-created by two people, Palmer and Billy Markus.

On p. 16 he writes:

Jay wouldn’t admit he’d gotten lucky. He acted like his Dogecoin score proved his astute understanding of crowd psychology. Even after he moved on, I didn’t. I started seeing crypto bros everywhere. They were acting like the rising prices of the coins proved they were geniuses. And their numbers were growing.

This is an excellent observation. And when you attempt to engage some of them on social media more than a few will retort, HFSP!

On p. 17 he wrote:

Crypto didn’t hold the same appeal for me. I’d resisted the topic whenever it came up at work. It seemed so obvious. The coins were transparently useless, and people were buying them anyway. A journalist composing a painstaking exposé of a crypto scam seemed like a restaurant critic writing a takedown of Taco Bell.

This is one of the many witty comments, I’ll try not to post all of them because you should grab a copy of the book and find them yourself.5

On p. 18 he writes:

The answer was not much. But I did know they were called “stablecoins” because, unlike coins with prices intended to go up, they were supposed to have a fixed value of one dollar. That was because each coin was supposed to be backed by one U.S. dollar. The biggest stablecoin by far was called Tether.

This is a decent high level description of a centrally-issued pegged coin. In academic literature it is still probably more common to see “fixed” than “pegged” but either works.

With that said, I do think it is confusing – as a reader – to be introduced to Tether and not USDT. Later on it does get confusing, because the author uses Tether to describe both the issuer (Tether LTD) and the medium-of-exchange (USDT). I had a similar nitpick about the same type of usage in Easy Money, where the authors inexplicably do not fully define what a stablecoin is or mention how there is more than one (beyond Terra).

On p. 18 he writes:

I couldn’t tell which country’s authorities were overseeing Tether. On a podcast, a company representative said it was registered with the British Virgin Islands Financial Investigation Agency. But the agency’s director, Errol George, told me that it didn’t oversee Tether. “We don’t and never have,” he said.

One of the strengths of this book is that the author routinely gets a direct quote from people involved on the regulatory and law enforcement side of the table. Strangely we do not see anything like that in Easy Money.

On p. 19 he writes:

There were plenty of critics who speculated that Tether was not actually backed by anything at all.

Another refreshing sub-narrative in this book was the lack of a sub-narrative surrounding “critics” that occurred throughout Easy Money. That is to say, Faux does not attempt to put anyone on a pedestal, least of all, people marketing themselves as “critic” or “skeptic.”

On p. 20 he writes:

“In a panic, everything collapses and they look to the federal government to bail them out,” one attendee at Yellen’s meeting told me. “If the crypto market was isolated, maybe we could live with that. But hiccups in one market start to translate into other markets. These are the things we’re paid to worry about.”

The author referenced a series of important regulatory meetings that occurred in the summer of 2021 and actually got a direct quote from an attendee. Top notch stuff, no guessing games or reliance on clout chasers on Twitter.

Chapter 2: Number Go Up Technology

Great intro to the chapter on p. 22:

The Florida crime novelist Carl Hiaasen once wrote of his home state, “Every scheming shitwad in America turned up here sooner or later, such were the opportunities for predation.” In his books, the scheming shitwads are crooked cops, corrupt politicians, and the cocaine traffickers who financed much of Miami’s skyline. But plenty of people at Bitcoin 2021, the crypto conference I’d come to attend, met the description.

On p. 22 he writes:

I was deeply skeptical about cryptocurrency before I arrived, and what I had been learning about Tether wasn’t doing much to dispel those doubts.

Unlike the previous two book reviewed, the author does not make or spin this “skepticism” into some form of identity.

On p. 22 he writes:

My plan was to listen politely to a bunch of tech bros pitching their apps, and then to ask them what they knew about Tether.

And he did!

On p. 22 he writes:

The attendees wore T-shirts with crypto slogans, like Have fun staying poor or HODL, a meme about never selling crypto derived from a typo for the word “hold.”

He got it right! Unlike the previous two books reviewed, Faux discovered “HODL” was a typo from a drunkard.

On p. 24 he writes:

The mayor equated Bitcoin’s doubters with his city’s skeptics, who liked to needle him about climate change by pointing out that streets flooded even on sunny days. As it so happened, during the week of the conference, the U.S. Army Corps of Engineers had released a report calling for a massive, twenty-foot-high seawall across Biscayne Bay, blocking the ocean views of the city’s financial district. “You guys see any water here? I don’t know, I don’t see any water here,” Suarez joked to the crowd.

Can’t say I follow Suarez closely but does he typically use dark humor?

On p. 24 he writes:

Their bête noire was “fiat money.” That means money printed by central banks—in other words, pretty much all money in modern times.

I need to be pedantic (since that’s my calling card). In the U.S., the vast majority of “fiat money” is actually created by commercial banks not central banks.6

On p. 25 he writes:

A blockchain is a database. Think of a spreadsheet with two columns: In Column A there’s a list of people, and in Column B there’s a number representing how much money they have.

Hurray, a definition. Now I didn’t care much for the example the author used but unlike the previous book review, he gave it the good ol’ college try and it conveyed the necessary information to the reader.

On p. 25 he writes:

With the Bitcoin blockchain, the numbers in Column B represent Bitcoins.

Hurray, countable blockchains. Unlike several other books I have reviewed in the past (especially in the 2016-2017 era), Faux quickly explains to readers that there is more than one blockchain. Two sentences later he mentions the Dogecoin blockchain.

In other words, unlike Easy Money and Popping the Crypto Bubble, Faux does not conflate Bitcoin with every other blockchain.

On p. 26 he writes:

The technical innovation of blockchain is that it lets customers get together and maintain the list themselves, with no banker involved. If I want to transfer 1,000 Bitcoins from my account to someone else’s, there’s no handsy banker to call. So instead, my computer broadcasts the transaction to all the computers that run the Bitcoin network, sending all the other Bitcoin people a message that says, “Hey, I’m transferring 1,000 Bitcoins to another account.”

This is a decent example. But I think a more accurate verbiage would be “intermediary” instead of “bank” (because there are a variety of intermediaries in finance).7

On p. 27 he writes:

The solution that Bitcoin uses to prevent this “double-spending problem” is called “mining,” and it’s incredibly complicated and confusing. It also uses so much electricity that the White House has warned it might prevent the United States from slowing climate change. It’s like something out of the world’s most boring dystopian science-fiction movie.

This page is about as much as readers are provided into the topic of mining. That’s a little disappointing, since the market still lacks a long-form, non-hagiography on the topic. But that’s someone else’s calling for now and would not have really fit well into the flow of the book.8

On p. 28 he writes:

The difficulty of the game automatically increases when more miners enter it.

Technically the difficulty changes (increase or decrease) is based on hashrate, not on entry or exit of “miners.” That is to say, if readers were to download and use a Bitcoin mining client on their home computer, their mere entry would not immediately change the difficulty rating because the amount of hashrate a home CPU brings to bear is miniscule relative to the ASICs housed in warehouses by existing participants.

On p. 29 he writes:

Silk Road was Bitcoin’s first commercial application. Drug consumers didn’t set up their own mining rigs before going shopping on the dark web. They bought Bitcoins for cash on rudimentary exchanges. The demand started driving up the price.

To his credit, unlike Easy Money, Faux does not sensationalize and claim Silk Road was the “most successful onboarding app” for Bitcoin. Maybe it was, but Faux doesn’t get bogged down in histrionics.

On p. 30 he writes:

The system depends on economic incentives. The miners who confirm transactions have made such a large financial investment—in buying computers to compete in the guessing game—that it wouldn’t make economic sense to undermine Bitcoin by entering false transactions. But that also means it does make economic sense to run tons of computers to guess random numbers in hopes of winning the Bitcoin reward. As one person famously put it on Twitter, “Imagine if keeping your car idling 24/7 produced solved Sudokus you could trade for heroin.”

Solid quote. Nice reference to this funny tweet too:

Source: Twitter

On p. 30 he writes:

That is as bad for the environment as it sounds. Once Bitcoin’s price started rising, competition drove out the hobbyist miners. Within a few years, companies were selling specialized computers that were extra good at the guessing game. Miners started operating whole racks of them. Then warehouses full of racks.

This is a pretty concise way of describing the absurdity of the value leaking from the ecosystem, to the benefit of state-owned energy grids, A/C manufacturers, and semiconductor companies.9

On p. 31 he writes:

Other coins would adopt different authentication systems that used far less electricity, but Bitcoiners opposed any change to Nakamoto’s mining system. There was no way to reduce mining’s energy use.

This is a fantastic nuance that other authors, especially in both Easy Money and Popping the Crypto Bubble, fail to distinguish. The ossification and intransigence by the Taliban wing of Bitcoinland is real. For instance, the core developers (and foundations) behind both Zcash and Dogecoin have announced plans to migrate away from proof-of-work and adopt proof-of-stake.

While there have been (dubious?) efforts such as “Change the code” to kickstart something similar for Bitcoin, the bottom line is that it is the centralized exchanges that ultimately call the shots because they control the BTC ticker symbol. And during the blocksize “civil war,” several major ones said they would only recognize the chain that Bitcoin Core worked on. And that clique is anti-proof-of-stake. There will be a test after this book review, so take notes and pay attention!

On p. 31 he writes:

The fundamental absurdity of all this is that the numbers in the Bitcoin blockchain don’t represent dollars, or even have any inherent tie to the financial system at all. There’s no reason why a Bitcoin should be worth more than a Dogecoin or any other number in any other database. Why would someone burn massive amounts of coal just to get a higher number written in the blockchain for their account?

Preach it, brother! As Barney Gumble might say, just hook it to my veins.

Source: Twitter

On p. 31 he writes:

But, of course, just because the supply of something is limited doesn’t make it valuable—only 21 million VHS tapes of Pixar’s Toy Story were made at first, and you can get an original on eBay for three dollars.

Bingo! Without persistent and/or increased demand, a deterministic supply is mostly meaningless.10 Empirically we see that with hundreds (thousands?) of supply capped coins that fail to reach the proverbial NGU moon.

On p. 31 he writes:

For Bitcoin believers, the rising price became its own justification. On stage in Miami, many of the speakers resorted to a sort of illogical reasoning: The price of Bitcoin will go up because it has gone up. They wielded this circular argument to ward off doubt and call forth a future of infinite bounty. It became a mantra: Number go up.

To be fair, this mantra pre-dates the soothsayers at Bitcoin Miami by years. In fact, one could argue that the origins of Bitcoin maximalism – circa March 2014 – incorporated this fallacious circular view.

On p. 32 he writes:

“NUMBER GO UP,” declared Dan Held, an executive at a crypto exchange called Kraken, on stage at Bitcoin 2021. “Number go up technology is a very powerful piece of technology. It’s the price. As the price goes higher, more people become aware of it, and buy it in anticipation of the price continuing to climb.”

A sociologist or two could write a book on Held and his former colleague, Pierre Rochard, for the crazy things they have said to defend (and promote) Bitcoin maximalism.11

On p. 32 he writes:

Max Keiser, a Bitcoin podcaster, emerged first, in a white suit and purple sunglasses, to pounding EDM. “Yeah! Yeah!” he screamed, pumping his fists, as the dance music built to a drop. Elon Musk had recently said that Tesla would not accept Bitcoin due to its environmental impact, and Keiser was raging like the billionaire had run over his dog. “We’re not selling! We’re not selling! Fuck Elon! Fuck Elon!”

During my review of Chapter 6 of Easy Money, I linked to this exact string of expletives as something the authors missed by attending the 2022 edition of Bitcoin Miami and not the 2021 that Faux witnessed.

On p. 33 he writes:

A more accurate description would be that Saylor was the biggest loser in the room. He didn’t mention it during his talk, but his software company, MicroStrategy, had nearly gone bust during the dot-com bubble, back when the internet counted as a hot new technology. In 2000, just before it popped, he told The New Yorker: “I just hope I don’t get up one day and have to look at myself in the mirror and say, ‘You had $15 billion and you blew it all. There’s the guy who flushed $15 billion down the toilet.’ ” Right afterward, he lost $13.5 billion.

Solid quote. Strangely, while Saylor does get another couple of paragraphs, Faux missed out on informing the readers that on August 31, 2022, the Attorney General for DC announced it was suing Saylor for evading more than $25 million in taxes. Surely readers would find that interesting?12

On p. 34 he writes:

Some people speculated that what Tether called “commercial paper” was really debt from exchanges like FTX. That would explain why no one on Wall Street had dealings with Tether. FTX could simply send Tether a note saying, “I promise I’ll pay you $1 billion,” and Tether could zap over 1 billion coins, and no one would be the wiser.

Of all the discussion surrounding Tether, the commercial paper (CP) angle was the one that felt like it lacked a sufficient bowtie for readers. Later he does mention how Tether announced it planned to move entirely away from CP and acquire Treasuries instead.

However I felt that – as mentioned in the reviews of both Easy Money and Popping the Crypto Bubble – it would be helpful to the audience to briefly explain the recent history of shadow payments and shadow banking in the U.S., starting with PayPal and Money Market Funds (MMFs) which trail blazed the path that Tether LTD and other centralized pegged coin issuers followed.13

Source: Twitter

On p. 35 he writes about SBF and Tether:

“We’ve wired them a lot of dollars,” he said. He also told me that he’d successfully cashed in Tethers, transferring the digital coins back to the company and receiving real U.S. dollars in exchange, though the process he described sounded a bit strange. “This is going through three different jurisdictions, through intermediary banks,” he said. “If you know the right banks to be at, you can avoid some of these intermediaries.”

The long and the short of redeeming these centrally issued pegged coins is you have to rely on legacy infrastructure (wiring). I have never attempted to redeem USDT or USDC, but a number of acquaintances have, and following the collapse of SEN and SigNet it involves ol’ fashioned wires.14

On p. 36 he writes about Mashinsky and Celsisus:

But then he described what sounded very much like monkey business. Tether, in addition to investing in Celsius, had lent more than $1 billion worth of its coins to the company, which Mashinsky used to invest in other things. Mashinsky claimed this was safe because for every $1.00 worth of Tethers he borrowed, he put up about $1.50 worth of Bitcoin as collateral. If Celsius went bust, Tether could seize the Bitcoins and sell them. He told me this was a service Tether offered to other companies too.

So I don’t want to be perceived as carrying water for Tether (or Celsius) – I stand by all my critical comments I have made of both of them in the past – but this type of arrangement is kind of what commercial banks do. And that’s probably the angle – shadow banking – I would have probed more.

On p. 37 he writes:

“Somebody is lying,” Mashinsky said. “Either the bank is lying or Celsius is lying.” I was pretty sure I knew who was lying, and it wasn’t J.P. Morgan. I made a mental note to investigate Celsius when I got back to New York.

Why not both?

As mentioned in my review of Easy Money, 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 author was looking for a large unblemished regulated financial institution, there probably is none. But to be fair, this was Mashinsky’s example the author was responding to.

On p. 37 he writes:

Mallers explained that he had gone to a beach town in El Salvador because a surfer from San Diego was teaching poor people there about Bitcoin, which was somehow going to help them stop being poor.

Ha, this is great. And sad too.

On p. 37 he writes:

Rather than telling his citizens first, he had chosen to reveal a major national policy to a bunch of Bitcoiners, in Miami, Florida, in English, a language most Salvadorans don’t speak.

Oof.

On p. 38 he writes:

I didn’t get it. There was a reason no one used Bitcoin to buy coffee—it was complicated, expensive, and slow to use. And what would happen if poor Salvadorans put their savings in crypto and then the price fell? But the audience was rapt. As I scanned the crowd, I saw that Mallers wasn’t the only one wiping away tears.

If there is a movie version of this book, need to have Steve Martin-like entertainer on stage ala Leap of Faith.

On p. 39 he writes:

Not everyone I spoke to in Miami was a Bitcoin cultist. The biggest users of Tether were professional traders at hedge funds and other large firms, and I interviewed several of them too. What they explained to me was that for all the talk of peer-to-peer currency, and the ingenuity of a way to transfer value without an intermediary, most people weren’t using cryptocurrencies to buy stuff. Instead, they were sending regular money to exchanges, where they could then bet on coin prices.

Compared to the two previous books, it is nice to see the author use a nuance around “Bitcoin cultist” — because not every coin or token encourages the sort of maximalism we see from Dan Held and Pierre Rochard. And empirically not every public chain project is attempting to reinvent “money.”

On p. 39 he writes:

Even so, many had their own conspiracy theories about Tether. It’s controlled by the Chinese mafia; the CIA uses it to move money; the government has allowed it to get huge so it can track the criminals who use it. It wasn’t that they trusted Tether, I realized. It was that they needed Tether to trade and they were making a lot of money doing it. There was no profit in being skeptical. “It could be way shakier, and I wouldn’t care,” said Dan Matuszewski, co-founder of CMS Holdings, a cryptocurrency investment firm.

I’m not endorsing CMS but I’ve found it weird to see certain Tether Truthers single out CMS as part of the inner ring of the Tether cabal.15 One of its most vocal members even accused Matuszewski of lying about redeeming USDT for real money, and then deleted the tweet. Maybe CMS (and Matuszewski) are indeed at the center of the Tether cabal, but the burden-of-proof is on the Truthers (the self-deputized prosecutors) to provide evidence.

Chapter 3: Doula for Creation

One of the most interesting things about this chapter is the author described, what I believe may have been the first bookform exploration into the history of Mastercoin.

I’ve read a number of interviews of Brock Pierce in the past. I even briefly met him in late 2014 at a house party in the Bay area. But this was the most colorful description of his social circle, drugs, dreams and all.

For instance, on p. 42 he writes:

I decided to mingle and ask the guests what they knew about our absent host. A beautiful woman told me she’d spent a week with Pierce in the Colombian jungle, where he’d bought land to protect it for Indigenous people. “It’s amazing what he does,” she said. Another man told me Pierce was building a spaceport on an old army base in Puerto Rico. An obnoxious guy who described himself as a “futurist” told me a story about a time in Ibiza when Pierce went three days without sleeping. “He’s surrounded by people who are benevolent dolphins and not sharks,” he said. He then asked me to smell a pastry for him before he ate it, telling me he was allergic to raspberries.

Ha! Everything in this paragraph is worth a couple chuckles because anecdotally it sounds true.

On p. 43 he writes:

At some point, a man at the other end of the table began bragging loudly about a cryptocurrency called “Let’s Go” or “Let’s Go Brandon,” a slogan that, through an almost inexplicable memeification process, had come to stand for “Fuck Joe Biden” among Trump supporters. The man, who I later figured out was a hedge fund manager named James Koutoulas, announced to the table that his plan for the coin was “dumb but it’s working.” A month earlier, a podcaster had presented Donald Trump himself with five hundred billion of the tokens, and just that afternoon, Donald Trump Jr. had made a cryptic post on Twitter seemingly referencing the meme coin. “Is that allowed?” someone asked. “They’re allowed to make money,” Koutoulas said. “Fuck the SEC.”

I had never heard of Koutoulas and I checked my email. A former colleague sent a spreadsheet in September 2018 with Typhon Capital Management listed as a “crypto fund;” that’s the fund Koutoulas founded.

On p. 43 he writes:

A doctor from Boise, Idaho, and a Bitcoiner were talking about the coronavirus vaccine and “medical freedom.” The Bitcoiner refused to tell me his name. “Real G’s move in silence,” he told me, with a high-pitched laugh.

Sounds par for the course. I’ve lost count how many supposed “cypherpunks” want to have it both ways: cash in off their notoriety and live it up large all while being “anonymous.” Jameson Lopp immediately comes to mind: telling The New York Times how he made himself “vanish” and simultaneously getting CryptoDeleted, deleted.16

On p. 44 he writes:

None of the guests seemed to know one another. A crypto venture capital fund manager—wearing a mock souvenir T-shirt from convicted pedophile Jeffrey Epstein’s private island—joked about a scam that another yacht guest was running. A crypto public relations man offered what he called “Colombian marching powder” to a young woman.

So much oof in those three sentences.

On p. 46 he writes:

I realized I had walked in on a presentation for a timeshare that I would pay money not to join. It was also not the best setting for a long conversation. My tour guide soon sent me back downstairs. When Pierce and I did catch up, by phone, he told me he’d dreamed up the idea for a stablecoin back in 2013. He said he knew from the start it would change the course of history. “I’m not an amateur entrepreneur throwing darts in the dark,” he told me. “I’m a doula for creation. I only take on missions impossible.”

Someone should call the police, the author was subjugated to some cruel and unusual punishment.

On p. 49 he writes:

By 2013, Pierce was running one of the first Bitcoin venture capital funds. There still wasn’t much you could do with Bitcoins, and crypto remained largely the domain of geeks and hobbyists. But around that time, a man going by “dacoinminster” had posted a proposal on the popular message board Bitcointalk that would lead to the creation of Tether and make the entire $3 trillion cryptocurrency bubble possible. He called his idea “MasterCoin.”

I think one detail that could have been worth adding was that this fund was originally called Crypto Currency Partners and during the “bear market” of 2015 rebranded to Blockchain Capital. The fund typically wrote small checks (around $25,000 per deal) and had spurned at least one VC rule at that time: do not invest in startups that competed with one another (e.g., if you invest in one exchange in a specific jurisdiction, then do not invest in another exchange that served the same jurisdiction).

On p. 50 he writes:

Willett imagined that once he created the MasterCoin system, other people would come up with all sorts of ways to use it: coins that tracked property titles, shares of stock, financial derivatives, and even real money. None of the ideas were completely original—he told me he’d read many discussions of them on message boards—but he was the first to put them into practice.

Could be worth mentioning that there were several (three?) colored coin projects that existed around the same time, attempting to track similar off-chain wares.

On p. 50 he writes:

“If you think Bitcoin has a reputation problem for money laundering now, just wait until you can store ‘USDCoins’ in the block chain!” Willett wrote in 2012. “I think criminals (like the rest of us) will prefer to deal with stable currencies rather than unstable ones.”

Pretty prophetic. Although, unclear from his original post if Willett was thinking of any distinction between central bank-issued digital currency versus privately issued pegged coins (which is what we have ended up with so far).

On p. 51 he writes:

Willett’s plan was innovative. It was also illegal. What Willett did was a textbook example of what the U.S. Securities and Exchange Commission calls an “unregistered securities offering,” meaning that Willett was selling an investment opportunity without any of the usual safeguards. Willett told me that the agency probably would have fined him hundreds of thousands of dollars if it had noticed what he was up to. But luckily, the regulators weren’t reading Bitcoin message boards. “They would have made a terrible example out of me if they’d known what was coming,” Willett said, laughing. “Never heard anything from them.”

So both Willet and the author could be correct. But I think referencing or quoting a U.S.-licensed attorney would have made this a stronger paragraph.

On p. 51 he 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.)

This is one of those quotes I spit-the-coffee-out, so to speak. You see, in Easy Money, the authors never got a direct quote from anyone at Tether, Bitfinex, or the regulators who oversee them. It was a disappointment. In contrast, readers of Number Go Up get a chance to hear from all of the above.

On p. 52 he wirtes:

Tethers. Then Tethers could be transferred anonymously, like any other cryptocurrency.

Pedantically, it isn’t truly anonymous: it is pseudonymously.

On p. 52 he write:

The problem was that Tether, like other cryptocurrencies, broke just about every rule in banking. Banks keep track of everyone who has an account and where they send their money, allowing law enforcement agencies to track transactions by criminals. Tether would check the identity of people who bought coins directly from the company, but once the currency was out in the world, it could be transferred anonymously, just by sending a code. A drug lord could hold millions of Tethers in a digital wallet and send it to a terrorist without anyone knowing.

I partially agree with this but believe a clarification should be added: in the U.S. That is to say, not every country has the exact equivalent of the “Bank Secrecy Act” which is what the author is referring to here.17

Source: Twitter

Three years later I would probably amend my own tweet to state on-chain activity can be surveilled by anyone running a node (tracing can be done at any time). But that surveillance sharing from CEXs depends on jurisdiction.

On p. 52 he writes:

“The U.S. will come after Tether in due time,” Budovsky wrote me in an email from a Florida prison. “Almost feel sorry for them.”

This was another spit-the-coffee-out moments. Unlike the authors of Popping the Crypto Bubble and Easy Money, Faux reached out to the creator of Liberty Reserve for a quote. And got a relevant one. Solid reporting.18

On p. 54 he writes:

When I spoke with Pierce on the phone, I asked him the central question: Was Tether actually backed up by real money? He assured me it was. He said Tether was preserving the dollar’s status as a global reserve currency. “If it were not for Tether, America would likely fall,” he said. “Tether in many ways is the hope of America.” But as he droned on, I realized Pierce had little information to offer about the location of Tether’s funds. My mind started to wander.

To me, this was the correct way to frame the conversation for the reader: Pierce is not an insider, so he probably does not have up-to-date inside info. I pointed this out in the review of Easy Money, where McKenzie and Silverman felt compelled to include Pierce’s information-free banter.

On p. 55 he writes:

But Pierce wasn’t going to help me find salvation. He told me that he’d actually given up on Tether in 2015, about a year after he started it. The currency had gotten almost no users, and it seemed likely it would be frowned upon by authorities. An SEC lawsuit, or a trip to prison, would prevent him from reaching his own destiny. “My view was if I made money from this thing it would prevent me from doing the work that I have to do for this nation,” Pierce said.

Unclear if Pierce truly believes the tales he spins.

On p. 55 he writes:

But if the exchange used Tethers instead of dollars, it wouldn’t need them. Potter pitched this idea to his boss at the exchange: Giancarlo Devasini, the Italian former plastic surgeon. He went for it. Devasini and his partners already owned 40 percent of Tether, and they bought the rest from Pierce’s crew for a few hundred thousand dollars. Pierce told me he handed over his shares for free.

This passage is another example for why I think Faux probably should have used Tether LTD to describe the issuer and USDT to describe tethers. A casual reader might assume that Devasini owns 40% of the USDT supply.

On p. 55 he writes:

After interviewing most of the people involved with Tether’s creation, I realized that they didn’t have the answers I was looking for. All of them said something similar: They definitely deserved credit for coming up with one of the most successful companies in the history of cryptocurrency, but they bore no responsibility for whatever the company was doing now.

Ha!

Chapter 4: The Plastic Surgeon

This is one of the shortest chapters, but involves some interesting color on Giancarlo Devasini that has not appeared in print before.

For instance, on p. 59 he writes:

This didn’t exactly match what I’d read on Bitfinex’s website. There, it said that Devasini’s group of companies brought in more than 100 million euros a year in revenue, and that he sold them shortly before the 2008 financial crisis. But Italian corporate records showed that the companies had revenue of just 12 million euros in 2007. Some of them even filed for bankruptcy. And none of the former employees I spoke to remembered Devasini selling them.

An example of “exit inflation”?

On p. 59 he writes:

What they did tell me was that in 2008, Devasini’s production facility was destroyed in a fire. Fuxa said it was caused by diesel generators that Devasini had set up because the local utility hadn’t provided enough power. “He basically built a power plant in the back and it went up in smoke,” Fuxa told me. But a newly unprofitable factory burning down in a mysterious fire struck me as a potential red flag, waving in the distance.

Oof.

On p. 60 he writes:

Tether called the lawsuit “meritless” and said it went nowhere.

Perhaps it is stonewalling, but a canned response is arguably better than simply not even reaching out to Tether LTD, which is apparently what a lot of the people who market themselves as “Tether Critics” have done. Solely engaging on Twitter has its limitations.

On p. 63 he worte:

Devasini was fascinated with finance. In a December 2011 post titled “The Shell Game,” he explained how Italian banks could avail themselves of billions of dollars of low-interest-rate funding. They could use it to gamble on anything, or to buy higher-yielding government bonds to make risk-free profits.

December 2011 was the middle of the European debt crisis (Italy was one of the i’s in PIIGS). Spoiler alert: since then, a number of Italian banks have struggled in what is labeled “the doom loop,” which includes the oldest Italian bank, Montei dei Paschi (which was bailed out). Would the banking sector be different if they had followed Devasini’s suggestion? Not sure, but is it a straight line between this “shell game” post and the setup of Tether LTD threeish years later?

Chapter 5: Hilariously Rich

On p. 66 he wrote:

He’d been left with a stockpile of 20 million unsold CDs and DVDs from his defunct manufacturing business. Now he decided to sell them for Bitcoin. He posted an ad on the Bitcointalk forum offering them for 0.01 Bitcoin each—about ten cents at the time. Marco Fuxa, his former business partner, told me that Devasini sold them all. If that’s true, and he kept the Bitcoins, their value would have later soared to more than $3 billion. “That’s how he got his money,” Fuxa said.

Big if true.

On p. 66 he wrote:

The first big exchange, Mt. Gox, repurposed a website created as a place to trade virtual Magic: The Gathering cards. (“Mt. Gox” stands for Magic: The Gathering Online eXchange.) Unsurprisingly, a former trading card website proved to be a bad custodian for billions of dollars.

It is interesting to see what different authors decide to include and omit to provide readers a backdrop to the industry they are covering. The collapse of Mt. Gox in 2014 unilaterally led to a 2+ year bear market and is frequently highlighted in mainstream press including this book. Yet neither Easy Money nor Popping the Crypto Bubble mentioned it even though it might have helped their arguments.19

On p. 67 he wrote about the aftermath of the 2016 Bitfinex hack (the 2nd one):

Trading increased so much that within eight months the exchange had earned enough to pay back its customers, either in cash or in Bitfinex stock. With this gambit, Bitfinex earned customers’ loyalty. And judging from what he’d do in the next few years, Devasini had learned a lesson: He could get away with bending the rules.

Even though I am not a trader, this always rubbed me the wrong way. If a regulated financial intermediary (like a custody bank) had done something similar in 2016, it is hard to see how the scrip would have been permitted to be issued. But we’ve seen some pretty strange things in traditional finance too ¯_(ツ)_/¯.

On p. 68 he writes about ICOs:

The hype was so powerful, it seemed like anyone could post a white paper explaining their plans for a new coin and raise millions. Brock Pierce, the Tether co-founder, promoted a coin called EOS, which was pitched as “the first blockchain operating system designed to support commercial decentralized applications.” It raised $4 billion. Yes, really. “I don’t care about money,” Pierce said in an interview around that time. “If I need money, I just make a token.”

Perhaps stranger is that Block.one (the entity that conducted the ICO) settled with the SEC in 2019 for $24 million with no disgorgement. Does this mean that EOS is in the clear now (in the U.S.)?

On p. 68 he writes:

These ICO-funded start-ups promised that blockchain would revolutionize commerce by enabling provenance to be tracked and verified. Even big companies like IBM and Microsoft started saying that they would put practically everything on the blockchain: diamonds, heads of lettuce, shipping containers, personal identification, and even all the real estate in the world. It seemed like blockchain-powered ICOs were the practical use that crypto had been waiting for. But there was one problem. None of this stuff ever advanced beyond the testing phases, if anyone bothered to even do that. Most ICOs were scams. And they weren’t actually an innovative form of fraud. ICOs made it easier to run a scam that’s about as old as the stock market. It’s called a “pump-and-dump” scheme.

I think this needs a paragraph break after the first sentence. Because while accurate, some readers may think that companies like IBM or Microsoft were directly involved in ICOs at that time (they were not).20

On p. 69 he writes:

With help from Mayweather, Centra raised about $25 million. But like most of the companies that raised money with ICOs, it was a total scam. It never issued its crypto debit card, or anything else at all. Even the CEO listed on its website didn’t exist—his picture was a stock photo. It would later be revealed that its founders, including a pot-smoking, opioid-addled twenty-six-year-old who ran a Miami exotic car rental business, had paid Mayweather $100,000 for his endorsement.

In contrast to Easy Money, where one of the authors talks about smoking pot and eating edibles a few times, this is the only place that marijuana is mentioned.21 Is that a good or bad thing? As Buddy Holly might say, Faux’s writing is square.

On p. 72 he writes:

By early 2017, Bitfinex was keeping its money in several banks in Taiwan. But the way the international financial system works, running an exchange required the cooperation of other banks too. Bitfinex’s Taiwanese bankers relied on other banks—known as correspondents—who acted as middlemen to pass money from Taiwan to customers in other countries.

One of my former colleagues at R3 previously worked at a large bank in Taiwan. When this publicized debanking occurred he mentioned in speaking with his former colleagues, senior managers who finally learned what was happening viewed it as scandalous because Bitfinex was flagrantly bypassing risk controls by opening up new accounts under different names.22

On p. 73 he writes:

But somewhere in the United States, an I.T. worker in his early thirties spotted the filing for the abortive lawsuit after it hit the court docket. He couldn’t believe what he was reading. Tether was supposed to be backed by real U.S. dollars in a bank. But in the lawsuit, the company itself admitted it had no access to the banking system. What was especially odd was that even after filing the case, Tether kept issuing coins. It created 200 million new ones that summer. But was anyone even sending in the corresponding $200 million, if the company didn’t have a functional bank account? The man signed up for Twitter, Medium, and other social media platforms under the pseudonym “Bitfinex’ed.” And what he started posting would create big problems for Devasini. Tether had spawned a powerful troll.

I believe one of the first times I interacted with Bitfinex’ed (prior to him losing a bet and blocking me), was when he proof read my post discussing the court case above: How newer regtech could be used to help audit cryptocurrency organizations.23

In retrospect, maybe I should have trademarked one of the subtitles: “Tether is not so tethered.”

Chapter 6: Cat and Mouse Tricks

On p. 74 he writes:

Four years later, when I started looking into Tether on my Businessweek assignment, Bitfinex’ed was still posting multiple times a day. His writing was conspiratorial, but it had struck a chord. Everyone in crypto would bring his posts up in conversation with me. Tether defenders tended to blame him for any negative news about the company. I’d seen things he wrote echoed in lawsuits and in mainstream reports. He seemed to know so much about Tether that I wondered if he worked for the company, or if he was a disgruntled government investigator. I arranged a meeting with him, on the condition I wouldn’t reveal his identity.

As mentioned in the Easy Money review, the first search result for googling “Bitfinexed identity” is to a five year old article that links to a Steemit article. Bitfinex’eds name is Spencer Macdonald.24 Back when I wrote long newsletters Bitfinex’ed 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.25

On p. 75 he writes:

He told me that he didn’t want to reveal his real identity because he’d gotten death threats from Tether defenders. As he worked himself up, the pitch of his voice rose higher.

That sucks, I have also received a slew of threats (and petty grievances) in the past too. The people who send those threats should receive some kind of consequence. Putting that aside, why does he still use this alias at this point since it has been googlable for years?

On p. 75 he writes:

By then, Andrew had lost me. I had been hoping to get new leads at this meeting, not an analogy drawn from a cartoon about anthropomorphic ducks. Andrew told me his mission to expose Bitfinex wasn’t personal. It seemed like it was. He said he imagined Kevin Smith—who played a slovenly hacker named Warlock who works out of his mother’s basement in a Die Hard sequel—portraying him in a movie. “I think it’s more humiliating for Bitfinex that way,” he said.

I agree with Faux, it seems a bit personal too. And I don’t think there is any shame in admitting that: several Bitfinex/Tether LTD staff (executives?) wronged you in the past — plus repeatedly lied in public — and you want to get even. But Macdonald – like the rest of the Tether Truther gang – likely has no inside information, he says as much to Faux. So how does Macdonald plan to humiliate them? In Easy Money, James Block dropped the alias (DirtyBubbleMedia) and still uses chain analytics to trace linkages, why not follow his lead?

On p. 77 he writes:

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.

This is a big oof. In Easy Money the authors put Macdonald/Bitfinex’ed on a pedestal, but never present a smoking gun. Perhaps there is one, but that rabbit hole took up valuable page space that Faux instead uses to interview a prosecutor from the NY AG office.

Speaking of speculation, Matt Levine recently hypothesized that Tether could be a lucrative business for one of the following reasons:

Source: Twitter

Number 2 is a possibility that Faux also independently surmises in the book, yet the authors of Easy Money do not, possibly because their sources (Bitfinex’ed/Macdonald) dismiss it a priori.26

On p. 77 he writes:

Betts explained that Noble wasn’t exactly a bank—it was an “international finance entity,” organized under looser Puerto Rican laws. His plan was to open accounts for all the major cryptocurrency hedge funds and companies. That way, they could easily transfer money between themselves without ever sending it out of Noble.

The Drake meme seems pretty fitting for this passage:

On p. 78 he writes:

The dispute got so heated that Devasini wanted to pull the company’s cash from Noble. Devasini’s deputy, Phil Potter, wanted to keep their money in the “international finance entity,” so Devasini and his other partners bought him out for $300 million. Potter took the payment in U.S. dollars, not Tethers.

That is a pretty big chunk of change. From its neighboring paragraphs, it appears this buyout took place in 2018. How did the partners who bought him out fund that buyout during this time period?

Chapter 7: “A Thin Crust of Ice”

This was a great chapter if for no other reason than we get to read in booklength (for the first time?), from a NY AG prosecutor involved in the Tether case. After reading this book, I think going forward reporters should ask Tether Truthers if they have ever reached out and/or spoken to any of the prosecutors. That seems like the bare minimum low-effort task to complete, otherwise it is just LARPing as a social media maven.

On p. 80 he writes about John Castiglione and Brian Whitehurst who were assigned to investigate the cryptocurrency market for the NY AG.

On p. 81 he writes about subpoenas:

The crypto industry responded with outrage. Four exchanges didn’t respond at all. Some of the others said they had no responsibility to police suspicious activity. Castiglione and Whitehurst decided to focus on Bitfinex, the crypto exchange owned by the same group that owned Tether. It had the most red flags. The company said it didn’t do business in New York, but one of its top executives—the chief strategy officer, Phil Potter—lived there. Castiglione sent a subpoena to some New York trading firms, and they informed him that they did use Bitfinex.

One of the exchanges that said they would not respond was Kraken whose representatives, at the time, said they did not do business in New York. Yet curiously, a year later, their head of trading – who was based in New York – sued them for stiffed compensation.

On p. 82 he writes:

This was, amazingly, even sketchier than it sounds. Crypto Capital advertised on its website that it enabled users to “deposit and withdraw fiat funds instantly to any crypto exchange around the world.” But it didn’t have any special technology. Instead, it was essentially a money-laundering service. Crypto Capital would simply open bank accounts using made-up company names. They’d tell banks they’d use the accounts for normal things, like real-estate investing. Then they’d let companies like Bitfinex use them for customer transfers. (Bitfinex would later claim that it believed Crypto Capital’s assurances that everything was on the up-and-up.)

Amazing, plus a funny parenthetical.

On p. 83 he writes:

Castiglione and his colleagues asked for proof that all Tethers were paid for with actual dollars by real customers. The defense lawyers acted affronted. But after some back-and-forth, one of the defense lawyers acknowledged that there had been what he called a “development.” They didn’t exactly come clean. Bitfinex had placed more than $850 million with a payment processor—Crypto Capital—and it appeared to be “impaired,” he said. Bitfinex had filled the hole by borrowing from Tether’s reserves. “I’m sorry, can you say that again?” Castiglione asked. Castiglione couldn’t believe it. Impaired seemed to be a euphemism for “gone,” and gone meant the exchange was insolvent and on the brink of collapse. On Wall Street, a trading venue in this situation would have to tell the world and shut down. It seemed like Bitfinex didn’t even plan on informing its customers. Castiglione asked the defense lawyers to leave so he and his colleagues could confer in private.

Future writers and reporters: if your book on Tether doesn’t have something as juicy as this statement above, do more digging because this is the bar to surpass.

On p. 85 he writes:

At first, Bitfinex’s lawyers said the deal to lend themselves Tether’s money was only pending. But after weeks of exchanging letters, they informed Castiglione that it had been completed, though they assured him it was a fair transaction negotiated without conflict of interest. They sent over papers documenting a $900 million line of credit from Tether to Bitfinex. Signing on behalf of Tether was Giancarlo Devasini. And on behalf of Bitfinex: Giancarlo Devasini.

They got the last laugh though, right? In the process of writing this, Tether LTD announced its latest attestations: about 85% of their reserves were now supposedly held in cash and cash-like equivalents (Treasuries). If they are able to pocket the 5%+ yield on Treasuries that is at least a couple billion in annual profit.27

On p. 86 he writes:

The settlement with New York required Tether to publish quarterly reports detailing its holdings, and to send even more detailed information to the attorney general. Castiglione hoped they would inspire someone to look more closely. But no regulators asked to see them.

This is interesting. Why have no other regulators reached out to see the documents? Did other regulators and law enforcement receive similar documents from subpoenas and thought the NYAG had outdated material?

Chapter 8: The Name’s Chalopin. Jean Chalopin.

On p. 91 he writes:

Tether’s lawyer, Stuart Hoegner, had a little bit more to say to me. In a video chat, he called Tether’s critics “jihadists” set on the company’s destruction and said their market-manipulation claims didn’t make sense. And, in an email, he said my reporting was “nothing more than a compilation of innuendo and misinformation shared by disgruntled individuals with no involvement with or direct knowledge of the business’s operations.”

It is not clear when Hoegner had the change of heart, or maybe it is just in external communications? You can always fire your client to save your book credibility.28

On p. 93 he writes:

That October, Businessweek published my account of what I found, with the headline “The $69 Billion Crypto Mystery.” (By then, Tether had issued 69 billion coins.)

Portions of the ~5,000 page article was reused throughout the book. Perhaps because the photo is black & white Jean Chalopin kind of looks like Chuck Norris.

On p. 93 he writes:

People read into the story whatever they wanted to believe. To crypto fans, it showed that Tether did in fact have at least some money, which was a positive. To those who were skeptical, the information about Chinese commercial paper was damning. I wasn’t sure what to make of the financial records myself. I tried digging into the details of their holdings. Many of the loans appeared to be legitimate loans to real companies. Others I couldn’t verify at all. But that was unsurprising given the low quality of data on Chinese corporate loans. Rather than a smoking gun, the records felt like another inconclusive clue.

He hasn’t received a smoking gun so far. Other authors on the beat take note, it’s okay to say you don’t have conclusive evidence one way or the other.

On p. 94 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.”

In Easy Money, the authors obliquely refer to a hedge fund (when interviewing James Block). I hypothesized it could have been Hindenburg Research or Citron (the former is mentioned later in this book). How many hedge have active trading positions on Tether solvency (one way or the other?)

On p. 95 he writes:

More recently, in March 2023, California’s Silicon Valley Bank collapsed after worry about its investment portfolio, amplified by a prominent podcaster, caused its customers, mostly start-up executives, to freak out.

Faux references a Financial Times article highlighting Jason Calcanis, who is a co-host of the All-In Podcast. Calcanis’ hysteria has led to a number of memes (and at least one bankrupt bank):

Source: Twitter

On p. 96 he writes:

But none of the analysts seemed much better informed than “Andrew,” the conspiracy theorist I’d met who posted as “Bitfinex’ed.”

Oof. Watch your notifications: FactFreeh, WillyBot, and other anonymous accounts will troll you if you point that out on the bird app.

On p. 97 he discusses the $1 million bounty from Hindenburg Research:

In November, we met in front of a hot dog cart by an entrance to Central Park. Anderson showed up wearing a hoodie. As we strolled down a path past children playing baseball, tourists taking photos, and a steel-drum band, he talked about what he could do with detailed documents on Tether’s holdings. Anderson said the bounty announcement hadn’t produced any great tips so far. I told him I might be able to help. Without revealing any details, I described the documents that I’d received.

I feel a little vindicated because in the past I have asked Tether Truthers, such as Jorge Stolfi, if they were so certain that Tether was acting in a fraudulent manner, why not collect the $1 million bounty. I have no affinity for Tether LTD (or Hindenburg) but I suspect it is because Stofli, and others, do not have actual evidence. Perhaps Tether LTD is still operating in a fraudulent manner, but using innuendo or hearsay is not a valid argument.

On p. 98 he writes:

“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.”

This is basically the opposite approach to Ben McKenzie, who in Easy Money writes about his $250,000 bet shorting the coin market… but doesn’t publicly disclose the bet until after the book is published. Conflict of interest?

Chapter 9: Crypto Pirates

This was a really solid chapter on SBF and FTX. In fact, I only had one quibble with it.

On p. 117 he writes:

Owning an exchange (FTX) and a firm that trades on it (Alameda) was an obvious conflict of interest. On Wall Street it wouldn’t have been allowed, due to the risk that the trading firm would be given preferential treatment or access to confidential information.

While I agree with the author, that this should not be allowed, it technically is not true in the U.S.

As mentioned in the review of Easy Money, an uneasy arrangement has been allowed at various eras in traditional markets: Glass-Steagall separated commercial banking from investment banking and was enacted 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. Even after the financial crisis and a myriad of debates, Glass-Steagall was still not restored. Even today, too big to fail banks still have these conflicts of interest.

So yes, some U.S. stock exchanges may not have that specific conflict of interest, but a number of other intermediaries do.

Chapter 10: Imagine a Robin Hood Thing

On p. 120 he writes:

There was one other thing that was incongruous with Bankman-Fried’s public image: the itty-bitty matter of U.S. law. If Bankman-Fried had stayed in Berkeley, many of the bets FTX offered would’ve been not quite legal. Or entirely, deeply illegal. Nearly all the coins it listed would have been deemed unregistered securities offerings, like MasterCoin. The exchange itself didn’t comply with SEC trading rules either.

That could be true, but it probably would have been a stronger statement if the author had quoted or cited a U.S.-trained securities lawyer on that matter.

On p. 122 he writes:

“You’ve built up a good reputation,” I said, needling him a bit. “You could probably run some crypto scam and make a few billion dollars right now. By your logic, wouldn’t that make sense?” “Charities don’t want that money,” he said. “Reputation is so important for everything you do. And as soon as you start to think about the second-order effects, it starts to look worse and worse.”

It has been interesting to read this book and write the review during the SBF criminal trial. The book itself was introduced as evidence when SBF took the stand. While the passage above didn’t make it into testimony, in retrospect it was a pretty big self-own.

On p. 126 he writes:

In fact, by then, Tether had grown to 79 billion coins. And it was becoming clear that Bankman-Fried was a big enough user of Tether that he wasn’t likely to tell me if something worse was going on. The short sellers and conspiracy theorists kept promising to reveal some big secret, but it hadn’t happened.

I have my own theory as to why some of the conspiracy theorists went off the deep end, turning their notoriety into a cottage industry for continual media engagement. But putting that cynical view to the side, reporters should ask these folks to provide the receipts. And move on to other sources if they do not.

On p. 127 he writes:

The funds were not in the possession of shadowy North Koreans or some other group of cyberterrorists. The stolen billions were traced to a couple in their early thirties who lived in downtown Manhattan, not far from my place in Brooklyn. Their names were Ilya Lichtenstein and Heather Morgan. Judging from social media, the two didn’t exactly appear to be criminal geniuses.

I recall the first time I saw those names in the press and I asked a couple (trader) acquaintances in NY if they had ever heard of them. No one had. The next chapter illustrates why this book is a solid entry into the True Crime genre.

Chapter 11: “Let’s Get Weird”

On p. 135 he writes:

In 2021, a total of $3.2 billion in cryptocurrency was stolen from exchanges and decentralized finance (or DeFi) apps, in which crypto traders make deals directly with one another. That’s a hundred times more than the total stolen in all bank robberies in an average year in the United States.

Bank robbers need to step up their game, those are rookie numbers.

On p. 135 he writes:

Back in 2015, Bitfinex had set up a new security system after it lost about $400,000 of cryptocurrencies in a hack. Other exchanges generally mixed users’ coins together and stored the private keys on computers that weren’t connected to the internet, a practice known as “cold storage.” Bitfinex’s new system kept each user’s balance in a separate address on the blockchain, allowing customers to see for themselves where their money was. It used software from the crypto-security company BitGo.

Some background: the day Bitfinex was hacked (a 2nd time), some anti-government commentators, such as Andreas Antonopoulos falsely claimed that it was the fault of the CFTC. Recall that a few months prior, the CFTC fined Bitfinex for violating the CEA.

Source: Twitter

There is only so much time of in the day to fact-check, so hats off to Faux for not stumbling down the well-worn “its the governments fault” excuse. Maybe it is sometimes, but not that day.

On p. 135 he writes:

Michael Shaulov, a former coder for the Israeli Intelligence Corps and co-founder of the crypto-security firm Fireblocks, told me hacks like these generally don’t require a high level of technical expertise. Often, he said, the hardest part is crafting an email that tricks an insider into opening a malicious attachment. “The social-engineering vector is key,” he said.

Over the years I’ve had a chance to speak with people involved at a couple of the companies mentioned in this chapter. And while I have heard a single person singled out, it was a little disappointing that the criminal case against Ilya Lichtenstein and Heather Morgan didn’t say who or what was compromised.29

On p. 138 he writes:

They returned after a few weeks and then a third time a few weeks after that. “You sure you’re in the right building?” the doorman asked. (At the time, police were investigating the death of a prostitute in the tower across the street—surveillance video had shown men rolling a 55-gallon drum that concealed her dead body out of the building.) The agents assured him they were.

Faux’s never ending attention to detail strikes again.

On p. 142 he writes:

The arrest was national news. It was the largest seizure of stolen funds ever. “Today, the Department of Justice has dealt a major blow to cybercriminals looking to exploit cryptocurrency,” Deputy Attorney General Lisa Monaco said at a press conference. The TikTok commentariat tore through Morgan’s music videos, and within hours Razzlekhan was already a social media legend, having air-humped her fanny pack into the ranks of famous grifters. “The Bitcoin crimes are nothing compared to calling this shit rap,” Trevor Noah said on The Daily Show.

The amount of podcasts, videos, and obscure magazines and newspapers that Faux must have digested is impressive. Pretty solid zingers elsewhere too.

On p. 143 he writes:

Years after the Bitfinex heist, a fifth of the missing Bitcoins were still unaccounted for. Roughly $70 million worth had been sent to Hydra Market, a Russian dark-web site. No one knew where the money went from there, but on Hydra, vendors called “treasure men” were known to exchange crypto for shrink-wrapped packets of rubles that they buried in secret locations. It was possible there were underground bundles somewhere in Russia, waiting for Morgan and Lichtenstein to dig them up.

Is it just a matter of time before people randomly start digging for bundles of burried rubles? Shouldn’t there be a prediction market for this type of degen activity?

On p. 144 he writes:

The Bitcoins had been worth about $70 million when they were stolen. Devasini and his crew stood to recoup billions of dollars. It gave me little confidence in their abilities to safeguard money that their Bitcoins ended up in the hands of a pair of idiots, but having the coins sitting locked up in the couple’s wallets was probably a lucky break.

Based on the numbers mentioned in this book, there is a possibility that those high up Tether LTD are quite well off at this stage. Although clearly not at the same strata as Colin Platt.

On p. 144 he writes:

I quickly found that Mashinsky had an interesting history. I’d found a 1999 article in a defunct tech publication in which he listed a few very different businesses that he’d tried out after moving to the United States: “importing urea from Russia, selling Indonesian gold to Switzerland, and brokering poisonous sodium cyanide excavated in China for use by gold miners in the U.S.” He also said in the article that he wanted to get into the business of whole-body transplants. “Give an old person a new body—keep the head, keep the spine, and re-create the rest,” he said.

In another universe Mashinsky has taken Brains-in-a-vat mainstream. There you get a free whole-body transplant on the condition that an hour a day you solve captchas. Years later he is sued and charged with digital tomfoolery, for stealthily making it 20 hours a day; he accidentally created the plot of The Cookie Monster.

Chapter 12: “Click, Click, Click, Make Money, Make Money”

On p. 149 he writes:

Stone took his money out of stocks and went all-in on Ethereum, eventually starting Battlestar, which was supposed to help investors earn a return on their crypto holdings through what it called “institutional grade Staking-as-a-Service.” (Don’t ask.)

While I like some technical nitty gritty, rather than bore readers (or botch it like other authors have), Faux punts on describing what “institutional grade Staking-as-a-service” is. And that’s okay. With that said, he does mention “yield farming” a couple of sentences later but doesn’t really define it in the book.30

On p. 150 he writes:

By then, the ICO boom was over. It was no longer plausible for someone to announce they were going to create Dentacoin, a cryptocurrency for dentists, and raise millions of dollars —a real thing that happened in 2017. DeFi was different. It was based on “smart contracts.” These are, basically, simple programs that run on the blockchain. Remember that the Bitcoin blockchain is a two-column spreadsheet, and MasterCoin, Ethereum, and the like allowed for adding new columns that represented new coins. Now imagine if the spreadsheet added functions. Instead of just allowing users to add Bitcoins to one person’s row and subtract them from someone else’s, these smart contracts enabled them to swap one kind of coin for another, or make a loan to another user.

I think this could be a little unclear for readers and a paragraph break should be made with “DeFi was different.” Also, while users can create and deploy new assets via Mastercoin (renamed Omni), it doesn’t have a virtual machine like other “modern” chains do so its functionality is very limited compared with Ethereum.31

On p. 151 he writes:

DeFi used these smart contracts to create decentralized, anonymous versions of exchanges like Sam Bankman-Fried’s FTX.

Probably more accurate to say pseudonymous.

On p. 151 he writes:

“DeFi may not exist in January,” Mashinsky wrote. “What we want is for every DeFi player to have a Celsius account, so when the Ponzi runs exhaust themselves they will all park their coins with Celsius.”

Wow, just wow.

On p. 154 he writes:

His description of life in Puerto Rico sounded like a montage from a crypto version of The Wolf of Wall Street: “dancing, partying, drugs, beach.” Stone set up two big screens at the dining room table. He rarely looked up from them, even when his host threw weekly parties. As people danced around the room, he’d stare at the screens and snort lines of ketamine. Other crypto traders would bring their laptops too. Some preferred Adderall or cocaine. Stone liked to say he was one of the largest players in DeFi, a friend who hung out with him then told me, often yelling about hacks or how much money he was making. “He’d type loud, like he wanted people to know,” the friend said.

On p. 155 he writes:

Because it was crypto, all that money was stored on Stone’s laptop. It was as if Stone kept a billion dollars in bundles of hundreds, just sitting on his friend’s dining room table. The account was protected by a password, but Stone grew paranoid. He couldn’t sleep for more than a few hours at a time. He’d stay up until three in the morning trading, then start again at six or seven.

I’m not a master of memes but pretty certain an appropriate one for the passage above is: are ya winning, son?

On p. 155 he writes:

Mashinsky was claiming Celsius was safer than banks, but the company didn’t even have a system for tracking what Stone and its other traders were doing with the money. As one Celsius executive wrote in an internal email in December 2020: “As things stand currently, Celsius does not have a clear, real-time, and actionable view of our assets and liabilities.”

SMH.

On p. 157 he writes:

Mashinsky argued that crypto was better than dollars, because inflation would inevitably erode the value of all government-issued currency. I told Mashinsky I didn’t have any savings in cash, so it wasn’t like I was sitting on a pile of money that was getting less valuable. And I wasn’t worried about the safety of my bank account.

That old chestnut. J.P. Koning wrote a pretty good debunking of a similar narrative.

Chapter 13: Play to Earn

On p. 162 he writes:

Lapina started using his earnings to buy more teams of blobs, and he hired other people in town to play with them on their own phones. He let them keep 60 percent of whatever they won in the game. Before long, Lapina had more than a hundred people battling for him, including teachers, his grandmother, and even a police officer, who Lapina had to talk out of quitting the force.

Wow, had no idea how “viral” Axie was at that time.

On p. 162 he writes:

“It’s actually the beginning of the metaverse, in our opinion, just hiding in a very cute little game,” Aleksander Larsen, the Norwegian co-founder of Sky Mavis, said on a podcast. “I actually believe that Axie has the potential to impact the globe very heavily with letting people interact with the global economy, actually exiting their prisons, where they are born.”

Filtering through podcasts for this gem. Sounds like something VCs Congratulating Themselves would find.

On p. 163 he writes:

The returns didn’t strike the Filipinos I talked to as unreasonable. But a more sophisticated investor would have realized the daily rate of return was 8 percent—way, way too good to be true. At that rate, with earnings continually reinvested for ten months, Lapina and everyone else who bought a single set of Axies would be trillionaires.

Finally, a scheme on par with PTK.

On p. 163 he writes:

The only thing that kept the Axie economy afloat was new players buying in.

Because I’m overly pedantic I would probably have written, “the only thing that kept the Axie economy afloat at this price level” because technically Axie (the game) is still alive today.

On p. 166 he writes:

Quigan told me she and her husband were considering going abroad to Dubai to seek better-paying jobs. But she still checks the price of potions daily. “I don’t get angry,” she said. “I’m still optimistic that sometime, somehow, it will still go up.”

Probably could print that quote on a shirt and sell it a coin conference.

On p. 166 he writes:

QUIGAN MIGHT NOT have been angry, but I was. Crypto bros and Silicon Valley venture capitalists gave Filipinos false hope by promoting an unsustainable bubble based on a Pokémon knockoff as the future of work. And making matters worse, in March 2022, North Korean hackers broke into a sort-of crypto exchange affiliated with the game and made off with $600 million worth of stablecoins and Ether. The heist helped Kim Jong Un pay for test launches of ballistic missiles, according to U.S. officials. Instead of providing a new way for poor people to earn cash, Axie Infinity funneled their savings to a dictator’s weapons program.

Not a good look Bob.

Chapter 14: Ponzinomics

On p. 170 he quotes Anthony Scaramucci:

“These people are unbelievable the way they dress,” he said. “I’m here in a Brioni, these guys are in Lululemon pants. These guys are moving into the future. These are some of the worst-dressed people I ever met in my life.”

Yea, it’s not the fly-by-night scams to be concerned about, it is the clothing choices.

On p. 171 he writes:

As Lewis went on, Bankman-Fried tapped the toes of his silver New Balance sneakers, sometimes pressing his legs with his elbows as if to hold them still. It seemed like Lewis saw him as another one of the truth-telling, system-disrupting outsiders he liked to write about. But the author’s questions were so fawning, they seemed inappropriate for a journalist. Listening from the packed auditorium, I started to question whether Lewis was really writing a book, or if FTX had paid him to appear. (Lewis later told me that he had in fact come to report for his book and that he was not compensated.)

Was Lewis provided flights on the FTX jet? Either way, Michael Lewis was unhappy with Faux’s reporting on this topic, telling The New York Times in its review of Going Infinite:

I’ve never met Faux but I do not think he is on trial for defrauding customers for ~$8 billion in losses. Who knows, maybe Faux has been moonlighting as a North Korean hacker. How else could he track down VIPs at art shows?

On p. 172 he writes:

At a party for a project called Degenerate Trash Pandas, I asked one coder if crypto would ever be helpful for regular people. “Why is it that you think that is important?” he said to me, in a tone of total sincerity. “I really would like to know.”

Socially useful dapps? Get out of here.

On p. 173 he write:

Another crypto executive showed me a digital image of a sneaker that he bought for eight dollars, which he said had grown to be worth more than $1 million. He told me that recently, all owners of these imaginary sneakers had been issued an image of a box, which was itself worth $30,000. When he opened the box, he found another picture of sneakers and another box, each of them valuable in their own right. “It’s this never-ending Ponzi scheme,” he said, happily. “That’s what I call Ponzinomics.”

Reminds me of that SNL sketch with Tim Meadows and Will Ferrell with a Bible and a bar of gold:

On p. 175 he writes:

It struck me that almost any of the companies I’d heard about would be good fodder for an investigative story. But the thought of methodically gathering facts to disprove their ridiculous promises was exhausting. It reminded me of a maxim called the “bullshit asymmetry principle,” coined by an Italian programmer. He was describing the challenge of debunking falsehoods in the internet age. “The amount of energy needed to refute bullshit is an order of magnitude bigger than to produce it,” the programmer, Alberto Brandolini, wrote in 2013.

Source: Twitter

Another solid Tweet reference. Unfortunately Community Notes was not around in 2014-2016 which I think could have headed off some of the nonsense narratives.32

On p. 180 he writes:

Van der Velde seemed annoyed. He hinted that there was something in Tether’s past that he couldn’t reveal. “It’s very easy to invite a journalist into your office when you don’t have any battle damage,” he said. “Tether saved the whole industry. We had to carry those heavy loads. Sam had the luxury of making a nice clean start. Sam never had to deal with that.”

I think this is partly why Tether LTD has been given a free pass by much of the industry: it has provided the necessary lubricant to cross the chasm. It is systemically important for the coin world.

On p. 182 he writes:

He refused and accused me of being insufficiently committed to my project. “How do you expect to write a book about crypto if you have only dedicated $600 to crypto?” Loney said. I told him it was pretty common for writers to write about, say, presidential politics without serving as president, or baseball without being able to hit a fastball. But he wasn’t convinced.

That reminds me of this interaction from a few years ago:

Source: Twitter

Six years later there is still a problem with conflating holding a de minimis amount of coins in order to test out say, how limit orders work on UniSwap V3 versus making it the bulk of your portfolio. You do not need to own an airplane to be a pilot or stewardess or flight instructor. It’s possible to be a blockchain researcher without having to own massive quantities of the coin you are studying.

Chapter 15: All My Apes Gone

On p. 186 he writes:

A common misconception about NFTs is that the buyer owns a unique, verifiable digital image. That’s not the case. There’s nothing stopping anyone from simply right-clicking Justin Bieber’s ape and downloading the image file to their computer. The replica is indistinguishable from the $1.3 million original, and perfectly usable for a profile picture. What a Bored Ape buyer pays hundreds of thousands of dollars for is not a digital ape cartoon—it’s the ability to prove they are the one who paid hundreds of thousands of dollars for a digital ape cartoon.

So I partially agree with the premise here: the way many art-related NFTs were marketed the past few years was if there was a unique digital image. In most cases however – such as with BAYC – the owners had to refer to URL pointers. But not every art-related NFT project followed that path; there is a small category called “generative art” that as the name suggests, is generated and/or store fully on-chain. See Slide 9 for some examples of projects whose assets reside fully on-chain.

On p. 193 he writes:

The process of buying the ape didn’t make me feel any better. It could only be purchased on an NFT marketplace using the cryptocurrency Ether. (That’s what the Ethereum blockchain’s coins are called.)

A pedantic rewording of the parenthetical: the word native should probably be inserted between blockchain and a singular coin.

On p. 193 he writes:

Once my money was on Coinbase, I had to trade it for Ether, which was easy enough. Coinbase works just like E-Trade, except that instead of Apple stock, you’re buying and selling cryptocurrencies. It’s not exactly what Satoshi Nakamoto had in mind when he invented the first peer-to-peer electronic cash system—Coinbase is simply taking the place of your online trading site.

The irony of many intermediaries involved in that trade lifecycle.

On p. 195 he writes:

Each offer charged me a “gas fee” of about three dollars, an annoying sum for a technology advertised as an improvement on credit cards. These are paid to the operators of the Ethereum network—similar to the rewards paid to Bitcoin miners—and vary with demand, sometimes spiking past a hundred dollars per transaction.

It would have been a massive distraction, but I think readers would have liked to know why there was a spike. Not that there needs to be a future edition, but a hypothetical footnote could discuss maximal extractable value (MEV), which is sometimes the cause for these spikes.33

Source: Flashbots

Chapter 16: It’s the Community, Bro

On p. 199 he writes:

The Mutant Cartel was his effort to build a community around the Mutant Apes, which he felt had been a bit overlooked by their creators. “It’s all the good stuff about being in a cult without any of the negative,” Messika said. “It’s genuinely beautiful to see this deep camaraderie.” I wasn’t sure about what he was saying, but I have to admit it felt cool to be part of his crew.

This is the closest Faux describes becoming part of a crew. This stands in contrast to Easy Money where the authors arguably lost objectivity by becoming too close to their sources.

On p. 200 he writes:

Comedian Amy Schumer’s set early in the evening was not a hit. She seemed embarrassed to be there and called the attendees nerds. “I don’t know what NFT stands for,” she said. “I’m assuming it’s, looking out, not fucking tonight, is that correct? Do I have that right?”

Nerds just gonna stand there and take that? Didn’t make an NFT of that NFT joke?

On p. 202 he writes:

Even assuming one was made, the licensing fees would likely be barely enough to cover the cost of one Bored Ape. To make everyone’s investments pay off, 10,000 movie studios would have to make 10,000 deals to make 10,000 cartoons about 10,000 similar-looking animals.

On p. 204 he writes:

The bestselling writer Neil Strauss wrote an impenetrable ape-themed book that was itself released as a limited-edition NFT. At least 2,000 copies sold for about $250 each. “Captain Trippy lay in his hammock at the back of a room, holding a Shaving Ape cigarette loosely in his right foot,” he wrote. “Some say it’s the reason for his brightly colored psychedelic skin and captain’s hat, so that he can be seen through the smoke.” I’m not sure if anyone has actually read the whole thing, but I made a $300 profit when I sold my copy.

Someone call the purity police: the author is flipping NFTs for big bucks!

On p. 205 he writes:

A month before ApeFest, Ripps had started to sell his own NFTs. He called them RR/BAYC. They were exact replicas of Bored Apes—in fact, since NFTs don’t actually contain images, just links to them, Ripps’s NFTs contained links to the exact same images. He offered his for way cheaper, about $200 each. Ripps told me he hadn’t ripped off Bored Apes—he’d created a new artwork by placing them in a new context. “The NFT isn’t the image,” Ripps said. “The NFT is a cell in the spreadsheet that’s in the blockchain that links to an image. No one is mistaking their apes for my apes.”

Well when you say it out loud that way, it does sound a little ridiculous. But… the pedant in me must protest: not all art NFTs require an external link (but most of them do).34

On p. 207 he writes:

I later learned from a legal document that Snoop allegedly owned a stake in Yuga Labs. I was almost relieved to find out he may have been shilling his own investment.

I lied, here’s another zinger.

On p. 207 he writes:

But I felt angry on their behalf. I wondered if Fallon felt any responsibility for promoting Bored Apes in his segment with Paris Hilton.

I empathize with the authors anger. I’ve attempted to confront people I felt were responsible for actively misrepresenting some scheme. But, and I say this as someone who has never owned a ritzy Ape or Mutant: those are Veblen goods. The only way to buy them was to fork over $20,000 for the cheapest. Unsophisticated retail (who apparently got raked on Axie) couldn’t meet that threshold. That’s not an excuse for Fallon but it’s in a different league.

Chapter 17: Blorps and Fleezels

On p. 212 he writes:

Kwon’s main coin was called TerraUSD. It was a stablecoin like Tether, intended to always trade for one dollar. But Kwon didn’t promise to back his coins with dollars in a bank account. Instead, TerraUSD was backed with a second coin that Kwon made up, called Luna. Since Kwon controlled the supply of Luna, he could simply create as many as needed out of thin air.

This is mostly true, except the part where Kwon controlled the supply of Luna. He may have engineered its parameters at genesis, but post-launch he did not appear to unilaterally control Luna’s supply any more than Satoshi unilaterally controlled the Bitcoin supply.35

On p. 212 he writes:

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.”

Part II is great episode. Coincidentally I referred to Part I in the review of Easy Money.

On p. 212 he writes:

The reason people bought into Kwon’s Terra-Luna plan is that TerraUSD coins could be deposited in a special crypto bank called Anchor, also controlled by Kwon, which paid a 20 percent annual interest rate. This raised obvious questions, such as “Where does the money to pay those interest rates come from?” and “This is a Ponzi scheme, right?”

I probably would describe Anchor as a lending protocol, so maybe a shadow bank? My autopsy of that collapse: Not all algorithmic stabilization mechanisms are the same.

On p. 213 he writes:

The Tether critics were getting excited. Bitfinex’ed, the anonymous critic who asked me to call him Andrew when we met at the bayside pool, tweeted more than sixty times that day.

I think after 50 tweets in a day the state of Florida requires social media users to go outside and touch grass.

On p. 216 he writes:

Kyle Davies, Zhu’s high school friend and co-founder, later said the lenders were so desperate to make loans that they asked for almost no proof that Three Arrows would be able to pay. “One of the last calls we did someone lent me almost a billion, off a phone call,” he said. “That was uncollateralized. That’s where the system was. People needed to get dollars out the door.”

In my review of Easy Money, I pointed out that the authors criticism of lending was shallow because it didn’t discuss how the centralized lenders were rehypothecating funds and/or providing uncollateralized loans. Faux found a podcast with one of the borrowers saying as much. This filtering of information from disparate media is part of the reason why Number Go Up is a superior book.

On p. 217 he writes:

Even companies that hadn’t lent to Three Arrows themselves took a hit. Gemini, a well-regarded exchange, turned out to have lent users’ money to a company called Genesis Global, which lent it to Three Arrows.

Source: Twitter

As mentioned in the Easy Money review, 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.

On p. 217 he writes:

As crypto skeptics David Gerard and Amy Castor wrote, the industry was like an inverted pyramid whose tip rested on a box of hot air—Kwon’s Ponzi scheme. When the box crumpled, the pyramid came falling down.

What are crypto skeptics? This is the first and only time the author uses that phrase. There a number of other people who have provided critical views without marketing themselves as “crypto skeptics.”

On p. 216 he writes:

The losses hit everyone in crypto. Michael Saylor, the laser-eyed crypto prophet who was the star of the Bitcoin conference in Miami, stepped down as CEO of his company, MicroStrategy, after it lost almost $1 billion on its Bitcoin bet.

And was charged with tax evasion by the DC AG four weeks later.

On p. 221 he writes:

Like Chappy, many of the investors I talked to said they were still committed to crypto. It seemed to me like they just didn’t want to admit they’d been wrong. “To me it’s not about the money at all, it’s about the future,” an emergency room doctor in Lafayette, Louisiana, told me after he lost $800,000.

I’ve already used the Michael Scott cringe meme, it would be pretty apt here.

On p. 223 he writes:

I wondered why more people hadn’t cashed in their Tethers. There was clearly at least a small chance Tether might fail. Even someone who mostly trusted the company, despite all the reasons not to, would have reason to cash theirs in. Investors wouldn’t even have to leave the crypto world. Tether could be easily swapped for a competing stablecoin, called USDC, which was based in the United States and didn’t have the same checkered past.

This is the only time in the book where the author mentions another centralized pegged coin (which is one more than either of the previous two books did). I don’t think it is as cut and dry as Faux makes it out to be, for reasons discussed by J.P. Koning.3637 It would be a distraction for the reader, but if we were really to drill into this issue, could be worth looking which centralized stablecoin-issuers executives lobbied against the STABLE Act proposal. And who needed a bailout after SVB, Silvergate, and Signature banks collapsed.

Chapter 18: Pig Butchering

This is another must-read chapter in a must-read book. For instance, I learned that some of the scammers who randomly send beautiful pictures via the phone, are effectively slaves held in compounds in towns scattered around Cambodia. Yea, that stranger guy (or gal) that you have been sending messages to, might just be buttering you up for a coin-related scam.

On p. 231 he writes:

After being allowed to place a few winning bets or trades, the victim, feeling emboldened and thus vulnerable, would be convinced to make a really big gamble. That one they’d lose. Once the mark was gone, the store would be packed up. If the police came, they’d only find an empty room. It was, as the linguist David Maurer wrote in his 1940 classic The Big Con, “a carefully set up and skillfully managed theater where the victim acts out an unwitting role in the most exciting of all underworld dramas.”

TIL. Has Faux been holding that info nugget in his back pocket to be used in the right book?

On p. 232 he writes:

Icetoad and other volunteers from the Global Anti-Scam group told me that Tether refused to help them by freezing accounts or seizing stolen money, even when presented with evidence that an account held the proceeds of fraud. Tether clearly had the capability to help. In some cases, like hacks, Tether had frozen accounts and seized money. But when contacted about pig butchering, Tether would fall back on the excuse that it didn’t control the blockchain. Another Global Anti-Scam volunteer provided copies of several victims’ email exchanges with Tether.

This particular passage, while well-written, just seems a little difficult to follow because Tether probably should be written Tether LTD. Or maybe it is just me.

On p. 233 he writes:

To me, that sounded like a cop-out. When I sent my eighty-one Tethers to Vicky Ho’s platform, there was an entry in Tether’s database representing how much money I had, and another one representing how much Vicky Ho had. Another way of looking at it would be that Vicky Ho had an anonymous, numbered account at the Bank of Tether.

This is not quite true. Unless Vicky (or ZBXS, the platform she used) directly minted or redeemed USDT, then it is unlikely that particular unit ($81) ended up in a database managed by Tether. According to the book, ZBXS seems to be a fly-by-night exchange, and might not do any surveillance sharing. Also, as mentioned earlier, pseudonymous is probably more accurate than anonymous.

Source: The Block

But I do think Faux raises a good point. Tether LTD does actively blacklist addresses (see chart above).

What is the rhyme or reason for why some activity is permitted and others are not?

Source: Twitter

On p. 233 he writes:

I couldn’t believe that Tether was getting away with making its own rules for when it would cooperate with police. Imagine if the cops told a bank that it was holding stolen money and the bank said it wouldn’t return it because the thief didn’t shoot anyone. And, from what Icetoad and other members of his group were telling me, the criminal syndicates who ran pig-butchering scams were actually extremely violent. They told me that many of the people sending spam texts to potential victims like me were themselves victims of human trafficking.

I’m going to say something a little unpopular: I agree with what the author has written but I am not sure his analogy with banks refusing to cooperate with the police is correct.

In speaking with lawyers about this topic, one of the relevant concepts in property law is “nemo dat.” Physical cash is exempt from nemo dat because if every transaction required the cash holder to trace the provenance or lineage of the physical cash, then commerce would grind to a halt. Are centrally-issued pegged coins given the same exemption? I do not know. Perhaps someone could argue that because the coins utilize a public chain, we can (more) easily see the provenance to determine if they are a bona fide purchaser.

Again, I agree with the thrust of Faux’s argument and incidentally it is one of the reasons I surmised that centrally-issued pegged coins would become white-list only. But so far that prediction has been barely partially correct.

On p. 234 he writes:

I’d provided Vicky Ho’s address to Sanders before the meeting. Sanders pulled up a flowchart he’d made tracking transfers to and from the numbered account.

Source: CipherBlade

Above is a short flowchart included in the book. Strangely, neither Easy Money nor Popping the Crypto Bubble included any type of chart. I think readers will find this type of chart helpful, especially since many blockchains can provide those types of linkages by default.

Speaking of which:

Source: Blockseer

Above is a chart illustrating coin movements from Bitfinex to miners in August 2016.38 There is no need for a second edition of the book, but if there was for some reason, then this could fit into chapter 11.

Chapter 19: “We Have Freedom”

It’s a tight race with several other chapters, but this was perhaps the best chapter in the book, in part because it elicits a range of emotions for readers. Including anger and despair. Faux got on an airplane to investigate the leads he had identified. If there is one chapter that will make readers want to go full-on Rambo mode in the hills and valleys of Cambodia, it’s probably this one.

On p. 245 he writes:

Videos like these captured millions of views in Vietnam and turned Phong Bui into a local star. They had gruesome pictures of victims’ injuries and lurid titles like “The Story of Thuy Escaping from Hell on Earth and the Midnight Screams.” I’d paid to have them transcribed and translated. It seemed distasteful to turn human suffering into YouTube content. But they were one of the best sources of information on crypto-fueled human trafficking that I’d found. That’s how I located several of the victims I’d been interviewing.

I have heard content moderation at video sharing sites can really do a number on you. If I had to filter out this type of (flagged) material not sure how long I’d last on the job.

On p. 251 he writes:

“When they want to send to overseas, it’s convenient to send USDT,” he said. “It’s anonymous and it’s quite safe.”

Who am I to argue with a clerk at a money-exchange shop? A pedantic person, that’s who. It’s pseudonymous. If it were truly anonymous then ransomware operators and exchange hackers would demand it instead of Monero.

On p. 251 he writes:

This guy doesn’t care if Tether is backed by Chinese commercial paper, or anything at all, I thought. He just wants to trade crypto for bricks of cash, and not tell anyone about it.

Oof.

On p. 251 he writes:

Then, without asking for identification or even a name, he handed me a crisp $100 bill. I’d turned my crypto into cash, with no paper trail.

Faux point reminds me of something similar from J.P. Koning:

Source: Twitter

On p. 252 he writes:

Before we left, I spoke with Richard Jan, a veteran Taiwanese police officer who worked on the Big Fatty case. He said the Taiwanese government had rescued more than four hundred victims of human trafficking in Cambodia in 2022.

Jesus H. Christ. How many remaining victims were there?

On p. 254 he writes:

I wanted to do something, but Danielle and Dara had told me it was useless to report forced labor to the authorities. Local potentates were generally getting paid off by the traffickers. Rather than aid escapees, Cambodian officials would detain them for immigration violations.

Chapter 20: No Acceptamos Bitcoin

On p. 263 he writes:

I wanted to see the effects of Bitcoin in El Salvador myself. Before going, I met with Jack Mallers, the boyish crypto executive who’d introduced Bukele’s Bitcoin plan for El Salvador on stage at Bitcoin 2021 in Miami. Only ten months had passed since he burst into tears and told the crowd: “I’ll be there. We die on this hill. I will fucking die on this fucking hill!” But when I asked him how the experiment was working out, he said he couldn’t remember the last time he visited. He didn’t seem to be too torn up about it. “It’s very important to know that it’s not my project, you know,” he said.

Do we still use the term “poser” to describe these people?

Speaking of posers, a few weeks ago Faux did a reddit AMA. This response is germane:

Source: reddit

On p. 264 he writes:

Bukele was more committed to the bit. The forty-one-year-old president had become a crypto influencer, with four million followers on Twitter, where he dubbed himself “The Coolest Dictator.” He used government funds to buy $100 million worth of the cryptocurrency, and promptly lost half of it when the price of Bitcoin fell.

Not so fun fact: when Bukele was the toast of the Bitcoin world, Nic Carter uncritically hosted him in a Twitter Spaces, along with Alex Gladstein and Balaji Srinivasan.39 To my knowledge, the only high profile ‘coinfluencer’ to publicly condemn Bukele – and his association with cryptocurrencies – was Vitalik Buterin.

On p. 266 he writes:

When I mentioned Bitcoin at the first store I entered, the clerk snatched the bottle of water I was trying to pay for out of my hands. “Trash,” he said. “I will never use it.”

On p. 266 he writes:

García didn’t have much to say about Bitcoin. It was a way of drawing in tourists, he said. He converted their payments to dollars as quickly as possible. But he did have a story to tell about a different Bukele initiative: the gang roundup. It turned out being an unofficial Bitcoin mascot was not enough to protect him.

There is a similar (sad) story in Easy Money. What do Bitcoin promoters who point to El Salvador as a “success” have to say when these stories are highlighted?

On p. 267 he writes:

Bukele refused to speak with me. I texted with the legislator who’d posted the photo with Devasini, but he refused to talk about Tether, sticking to praising the president for his successful Bitcoin project, all the evidence to the contrary notwithstanding. “Our president is a brave visionary,” wrote the legislator, William Soriano. “El Salvador now leads the monetary revolution that will transform the world as we know it. Not just economically, but culturally as well.”

My Spanish is rusty but I believe Soriano is a sicofante?

On p. 269 he writes:

Bukele’s most prominent, if unofficial, Bitcoin advisers appeared to be Max Keiser, the podcaster who’d screamed “Fuck Elon!” on stage in Miami in 2021, and his wife and co-host Stacy Herbert. A few years earlier they were producing a conspiracy-theory-heavy news show on Russia’s state-owned RT network. Now, judging from social media, they were living large as champions of the state, eating at El Salvador’s best restaurants and flying in military helicopters to tour government crypto projects. Before my trip, I’d watched a segment on YouTube where they celebrated El Salvador’s Bitcoin law.

Oh it’s worse than that.

Source: Twitter

Shortly after his manuscript was sent for publication, an official “Bitcoin Office” Twitter account for El Salvador was established.

The greatest minds of their generation sitting in the official Bitcoin office of El Salvador. No problem is too small for these former Russia Today hosts.

On p. 269 he writes:

Herbert was cheerful and slightly less unhinged in person. She called Bitcoin “perfect money,” Bukele a “super-genius-like mathematician,” and said that Bitcoin City was part of how he would transform El Salvador into the next Singapore. But she wouldn’t share much about Tether and Devasini. She did mention there was one tangible sign of Tether’s presence in El Salvador: a mural that featured a Bitcoin volcano eruption and a tree with leaves shaped like Bitfinex’s logo. It was designed by Devasini’s much younger partner, an artist named Valentina Picozzi, and it was painted on a large wall near the entrance to a gang-controlled neighborhood. She said this was a sign of the commitment by Devasini and Tether’s other executives to helping the Salvadoran people.

Take that salty naysaysers and non-believers! “Perfect money” is going to rock your world.

Chapter 21: Honey is Better

On p. 272 he writes:

As I waited, the Italian critics and I respectfully contemplated Picozzi’s work: a blister pack of large orange pills with the Bitcoin logo on them—Bitcoiners like to say they’ve “taken the orange pill”—and a piece of white paper embossed with the phrase “Son of a bit.”

This is an example for why I contend – despite having been labeled a “critic” or “skeptic” for years – do not think it makes sense to market oneself as a “crypto critic.”

An “art critic” does not deny the existence of many different art forms, or materials used to create cart. In contrast, I have linked to threads above by folks like Jorge Stofli who contend that smart contracts mechanically do not work. The authors of the previous two books each market themselves as a “crypto skeptic” or “crypto critic” but painfully show in long form that they do not understand the subject matter they are writing on.

On p. 276 he writes:

Nearby, I spotted Tether’s chief technology officer, Paolo Ardoino, who was explaining his diet to another attendee. He looked fit, in a tight T-shirt tucked into slim gray dress pants. “I eat once a day. Only red meat,” he said. But he wasn’t willing to speak with me, even about the wonders of beef. “He’s the one that is writing bad things about us,” he told his wife, who was standing next to him. “Hello!” I said. She wouldn’t talk with me either.

A quick quasi related anecdote: when I confronted Chris DeRose for the first time at an American Banker event in 2015, I told him his (brighton36) harassment techniques on reddit were loathsome:

Source: reddit

Now obviously I’m aware that Faux is nothing like the misogynistic DeRose, certainly not a harasser. But I do know what it is like to be in social situations with people you disdain. My wife probably would’ve said the same thing to DeRose after she told off Marc Hochstein. 40

Chapter 22: Assets Are Not Fine

On p. 281 he writes:

FTX had seemed to me like a crypto casino, which lured investors to gamble on made-up coins and scams. But I hadn’t suspected that the casino’s counting room was short on cash.

To be fair, aren’t most cryptocurrencies made up, not just the ones at FTX? Arguably the only “non-made-up” coins are those that claim to link to real-world off-chain assets?

On p. 283 he writes:

The company, valued at $32 billion earlier in the year, was finished. Anyone who had left money on the exchange was completely wiped out.

Ackchyually, while Faux was correct when he submitted the manuscript, due to ongoing developments in bankruptcy FTX customers might now get 50 cents on the dollar.

Chapter 23: Inside the Orchid

On p. 290 he writes:

Talking in detail to journalists about what was certain to be the subject of extensive litigation seemed like an unusual strategy, but it made sense: The press helped him create his only-honest-man-in-crypto image, so why not use them to talk his way out of trouble?

During his house arrest this past year, SBF spoke with a variety of reporters and leaked Caroline Ellison’s journal to a pair of NYT reporters in order to discredit here and build up public sympathy.

Source: Twitter

We never find out which reporter it was (it was only two). The duo also wrote a couple of softball pieces on SBF earlier in the spring and summer. SBF did try to talk his way out of trouble, but ended up getting convicted on all 7 counts anyways.

On p. 292 he writes:

“As an individual, to make a bet where it’s like, ‘I’m going to gamble my $10 billion and either get $20 billion or $0, with equal probability,’ would be madness,” Rob Wiblin, host of an effective-altruism podcast, said to Bankman-Fried in April. “But from an altruistic point of view, it’s not so crazy.”

Another podcast to filter through. Imagine all the tweets the author could have written instead of listening to podcasts!

A year ago, just days before SBF is arrested, Faux interviewed some of the hangers-on left in the Bahamas. Here is one exchange on p. 301:

I threw out an easy question. “Why are you still here?” I asked. He started off by saying he wanted to help FTX’s customers. Then, unprompted, he told me that he thought there wasn’t much risk Bankman-Fried would ever get in trouble. “I firmly believe once somebody becomes a certain level of rich, they’re never poor again,” he said. “They don’t go to jail. Nothing bad happens to them.” I tried to keep a straight face as I imagined him telling that to the congressmen and prosecutors investigating FTX. His supercilious attitude and slovenly appearance reminded me of the disagreeable know-it-all Comic Book Guy from The Simpsons. His answer was so bad, it felt almost unfair to ask him tough questions. I gave him a second chance to say something nice about Bankman-Fried. “Are there specific things that make you think Sam is honest?” I asked. “Oh, I didn’t say he was honest,” the man said.

Unfortunately we do seem to have a two-tier justice system in the U.S., especially when it comes to prosecuting white-collar crime. However in this instance, SBF was arrested, extradited, and found guilty by a jury within a period of 12 months.

Epilogue

On p. 311 he writes:

Traveling around the world investigating crypto had given me a new appreciation for my Visa card. It worked instantly, with just a tap, charged no fees, and never asked me to memorize long strings of numbers, or to bury codes in my backyard.

No one has to like cryptocurrencies but this seems like sample size bias. I purposefully attempt to get credit cards that waive international transaction fees, some people may not qualify for those so they do get charged fees.

I mentioned this in the previous two book reviews: Visa and Mastercard are centralized entities operating centralized infrastructure. 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.41

Not that there needs to be another edition, but a future footnote 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.”

On p. 313 he writes:

Were we really throwing the full weight and resources of the U.S. government to prosecute some kid for manipulating the price of a coin named after a fruit? The situation seemed especially ridiculous given that I didn’t see any cases relating to money laundering for Chinese gangsters or facilitating human trafficking in Cambodia.

This is a good point. For instance, “Bob” is a dual citizen who used to be an executive at a large Bitcoin exchange based in China (not Binance) who knowingly allowed users from sanctioned countries (specifically North Korea) to trade on the platform in order to boost trading volume. He is still very active in this space as an executive for a mining company and regularly posts on social media. Yet Virgil Griffith went to prison.

On p. 313 he writes:

For most banks, this also meant that they had to start paying higher interest rates to their depositors. But Tether doesn’t pay interest to the people who own its coins. Whatever the company earns on its reserves is pretty much pure profit.

This is a good point. I mentioned this in a footnote for Chapter 8 but it is worth surfacing here: Circle shares revenue with partners (large holders), does Tether LTD do the same with large holders of USDT such as centralized exchanges?

The affable J.P. Koning recently pondered something similar:

Source: Twitter

It bears mentioning that in the “permissioned” blockchain world, the concept of passing interest onto holders becomes messy because depending on the jurisdiction paying cash holders (or CBDC holders) would result in the asset possibly being deemed a security which could create onerous reporting and taxing requirements.42

On p. 315 he writes:

Most of the short sellers betting against Tether gave up. Nate Anderson of Hindenburg Research, who had once tantalized me in Central Park by dangling his $1 million prize for information on Tether, failed to turn up the bombshell he was looking for.

Oof. Maybe there is a bombshell, but the problem with Easy Money in particular is that there is so much innuendo around Tether you could slice it with a toy butter knife.

NGU Notes

On p. 350 he writes:

Tether was presented with a 187-point fact-checking memo prior to publication and declined to respond to any specific questions about its history, its reserves, or its use by scammers and human traffickers. “The huge volume of corrections required would be tantamount to our rewriting Mr. Faux’s book for him, which is not our job,” a spokesperson for the company wrote. “Our attention is better focused on our customers and the success of the Bitcoin community.”

Wow, a 187 point memo. Did the authors of the two previous books provide Tether LTD with a similar memo?

Conclusion

This book was nearly flawless, and unlike the previous two books reviewed there are no fatal errors and certainly nothing that would be need to “rewriting” this book.

Unlike Easy Money, which seemed to have a substantive error every three pages, Number Go Up was a breeze to read. It was funny, it was witty, and most importantly it informative!43 In one book the author – who was relatively new to this space – scooped mainstream press as well as the conspiracy circles of Tether Truthers.44

I rarely recommend books, but in this case, have no qualms in doing so.

Endnotes

  1. I also recently reviewed Popping the Crypto Bubble by Diehl et al, which was the worst book on the topic, just filled with evidence-free polemics. It did include 41 pages of references but since the book relied entirely on second-hand information, its references should have been significantly longer. []
  2. Unless your name ends in Ellison or Singh or Wang, best to sit this one out. []
  3. In fact, his BusinessWeek article on Tether was published the month before so I probably would have changed the wording to un-short-change oneself. []
  4. One wonders if November 2018 was too early to seek a book deal to expand on: Systemically important cryptocurrency networks []
  5. One reviewer of this review said: “There are better examples of Taco Bell. For the analogy of useless overhyped food, he could have used protein shakes.” []
  6. Economists use aggregates such as M0, M1, and M2 to measure the expansion and contraction of the money supply. []
  7. Also, not a big deal, but by convention uppercase B is used to describe the network and lowercase b is used to describe the medium-of-exchange/unit-of-account. []
  8. Although, Tether LTD is actively investing in Bitcoin mining operations, including in Uruguay and Oklahoma. Perhaps the topic for a new chapter in the paperback version? []
  9. That’s all McKenzie and Silverman had to do: explain the history concisely. They scarcely even mention what was in the Riot mining facility, let alone how much resources it consumed. []
  10. Analysts and commentators have been discussing this with some Bitcoiners for years. []
  11. One day when I have some extra time, perhaps I will post the older newsletters that had some golden tweets of theirs. []
  12. The case has not gone to trial yet, but Saylor did lose a bid to quickly quash the suit. []
  13. For more on this topic, readers are encouraged to peruse the academic writings of Morgan Ricks and Rohan Grey. []
  14. Recall that Silvergate and Signature Bank both operated infrastructure – SEN and SigNet – that enabled participants to immediately transfer funds 24/7/365. When the parent banks collapsed, this infrastructure was turned off. []
  15. As mentioned in Easy Money, I am not sure who 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. []
  16. When I worked in Shanghai I met a guy who introduced himself as “John Teddy” who relied on using other people’s bank accounts because he didn’t want to go through he KYC process himself. In the summer of 2011 he did offer to sell me a few thousand bitcoins for a few thousand dollars; whoops on that missed opportunity, right? []
  17. Specifically Faux is probably referring to the “Travel” rule. See also: Gemini UK to Block Bitcoin Transfers To and From Non-Approved Exchanges []
  18. This quote actually first appeared in Faux’s BusinessWeek piece on Tether. []
  19. One reviewer of this review thought this could be because the authors of Easy Money arrived late to the scene and seem to have also relied on sources who were unfamiliar with certain large scams, hacks, and fraudulent schemes. []
  20. Both IBM and Microsoft have been actively involved in blockchain-related projects for years, but to my knowledge, nothing directly intersecting with an ICO. []
  21. Easy Money does not mention Centra at all, even though it could have helped strengthen the authors arguments. Coincidentally, Nathaniel Popper was the first mainstream reporter who wrote an exposé on how influencers such as Floyd Mayweather were being paid to endorse coins (without disclosing they were being paid). For instance, five months after his article appeared, the two founders of Centra were arrested. []
  22. I.e., someone inside was helping them navigate the controls and approval process. []
  23. It is worth pointing out that prior to its publication, I changed the title to the post due to possible reprisals from a now former colleague at R3 who wanted to control all external communications. []
  24. I previously mentioned his real name back in February 2022 in section 5. []
  25. He sometimes calls himself Andrew. Are there more aliases? []
  26. For what it is worth, I too have proposed scenario 2 in the past, and made a bet with Bitfinex’ed that it was a possibility. []
  27. It is unclear what revenue sharing agreements are in place. Recall Circle shares revenue with partners (large holders), does Tether LTD do the same with large holders of USDT such as centralized exchanges? Obviously this assumes that Tether LTD are telling the truth and/or not exaggerating. Perhaps they are fibbing. They claim to be publishing real-time reserve data next year. []
  28. I’m kind of joking, his book was decent for its time. And outside counsel can drop a client, but I believe he was inside counsel (GC even). A reporter should ask him what changed after his Bitcoin book was published. []
  29. Earlier this year, Wired published an interesting article on this topic, but the individual named by others does not appear in it. Maybe I was provided incorrect information? []
  30. Probably not a big deal considering some readers might have tried opening new checking accounts to take advantage of teaser rates, or attempted credit card churning. []
  31. Years ago I wrote a paper critiquing the notion that metacoins, specifically those that used Bitcoin, were fit for purpose for securing off-chain assets. []
  32. Although the fact that Jack Dorsey became a Bitcoin promoter kinda sorta feeds my tin foil hat theory for why “crypto” related activity was not heavily moderated. []
  33. Based on the authors description of how he acquired the art NFT, it is not apparent where additional MEV would have been extracted; he didn’t use a fungible token swap which is typically what gets reordered. []
  34. Ordinals, a Bitcoin-based tokenization protocol, received a lot of attention at the beginning of the year from the art NFT world due to the ability for users to “inscribe” data on-chain. []
  35. At least, that’s not an allegation made by law enforcement at this time. In a court filing, Jump Trading is stated as buying large quantities of UST to prop up its value during an earlier de-peg; still not the same thing as controlling the supply of Luna. []
  36. In the process of writing this, the FCA, the top financial regulator in the U.K., outlined proposed stablecoin rules that would effectively make issuers into narrow banks. []
  37. See also: Will the real stablecoin please stand up? by Anneke Kosse, Marc Glowka, Ilaria Mattei and Tara Rice []
  38. As mentioned in a footnote in Easy Money, I was a formal advisor to Blockseer which was acquired by DMG Blockchain. One of the prominent “crypto critics” amplified false information about myself last year including that I was not an advisor. A quick googling could prove that, why don’t they do it? []
  39. Probably not a huge surprise since both Carter and Srinivasan have publicly stated they are betting against the U.S. []
  40. For some reason Hochstein – who was editor at American Banker at the time – invited DeRose to provide A/V help at the event. Later Hochstein, among other things, unfortunately helped mainstream the nocoiner pejorative. []
  41. The Fed proposed cutting the current cap from 21 cents per transaction to 14.4 cents per transaction. []
  42. In 2017-2019, Project Jasper, World Wire, and the USC consortium, all had to tackle these thorny issues. []
  43. A reviewer of this review has a strong opinion on selective enforcement: “Overall, the book should have explored a central question: why the U.S. government with its correct and massive focus on money laundering, human trafficking, and terrorism financing is not proactively shutting down new crypto whenever it appears they way it would do if it was a physical dollar printing press. Why Tether, Ripple, Stellar and numerous other coins are allowed to propagate with no public disclosure of how they make money. Or why the PayPal stablecoin was allowed but Facebook’s Libra wasn’t. Other governments obviously don’t have the same moral imperatives to stop those types of activities, but why is the U.S. continually being reactive. I.e., the book doesn’t answer the question of how this was allowed to happen and how it will prevent it from happening again.” []
  44. It’s not a coincidence that a reporter relatively new to the space was able to accurately describe some of the tech: Fais Khan provided feedback and he is the author of another great book, The Billionaire’s Folly. []

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. []

Appendix to Parasitic Stablecoins

[Note: this is part of a standalone document written by Martin Walker in late 2019. It has been edited and condensed as it provides important considerations surrounding the topic of stablecoins. For more context, be sure to read the accompanying Parasitic Stablecoins article.]

Introduction

In spite of the relative immaturity of “Stablecoins” as both an asset class and as a form of financial sector technology, they has recently attracted a huge degree of attention from regulators, central banks, academia, the media and many parts of the financial sector. This attention has particularly intensified since the announcement by Facebook of its own stablecoin (Libra) on June 18, 2019.

Reportedly prompted by this, a joint committee was formed by central banks from the G7 group of major economies, the International Monetary Fund (IMF) and the Bank for International Settlements (BIS).1 This group reported its own findings, focusing on potential regulatory and economic impact in October 2019.2

Defining stablecoins can be challenging business because there are already a significant number of variations and some of the most discussed stablecoins are still in development. The most basic and broadest definition includes three main characteristics,

  • They are intended to perform at least two of the main characteristics of money, acting as a means of exchange and as a short-medium term store of value
  • They use some variant of Distributed Ledger Technology (DLT) to record and transfer ownership in a similar way to cryptocurrencies such as Bitcoin and Ether
  • They are intended to have a value that is relatively stable compare to major currencies.
Characteristics of stablecoins

While most research on stablecoins focuses on the economic and regulatory implications, the purpose of the this paper is to present an analysis of the practical implications for key processes such as payments and settlement, not to mention the potential impact on systems within financial institutions and overall financial market infrastructure. Stablecoins as both an asset class and to some extent a form of financial sector. Consequently they have challenges to adoption in terms of competing with the current world and interacting with it.


Stability and Collateral

The most straightforward step to create a form of digital currency that has a stable value is to peg its value to a financial asset with a stable value. Most stablecoins are pegged in value to a specific currency. Tether is pegged in value to the U.S. dollar on a one-to-one basis. Others are pegged (or proposed to be pegged) to a basket of currencies. Libra was originally proposed to be pegged in value to a basket consisting of the U.S. dollar, euro, yen, British pound and Singapore dollar. Other stablecoins attempt to achieve a higher degree of stability by pegging their value to a basket of assets, including cryptocurrencies, in the belief that diversification alone will achieve a higher degree of stability. Finally there are stablecoins pegged in value to commodities such as gold or oil. Claiming to have a pegged value does not (as is discussed below) mean a stablecoin is fully backed by funds in that currency.

Maintaining a peg is much harder than simply claiming a stablecoin has a value pegged to another asset or basket of assets.3 The degree of stability depends on

  • The type of reserves
  • The proportion of reserves relative to the amount of stablecoins issued
  • The nature of the issuer of the stablecoins
  • The legal structure including the protection of the reserves from the issuers creditors in the event of the issues default

Real or proposed stablecoins have reserves in one or more of the following types

  1. Deposits in a commercial bank marketed as providing one-to-one back – this is the backing claimed by Tether, the Gemini Dollar, Pax and many others.4
  2. Backed by the balance sheet of the issuer where the issuer is a bank. JPM Coin, at least based on initial news about the proposed stablecoin, would be supported by the balance sheet (i.e. the assets and capital of JPMorgan). From a credit and valuation perspective it should be broadly equivalent to funds deposited in a JPMorgan bank account.
  3. Backed by a basket of bank accounts and other financial assets – According to the Libra whitepaper the stablecoin would be supported by assets held by the Libra foundation consisting of bank deposits and short term debt denominated in a basket currencies, subsequently announced as the U.S. dollar, euro, yen, British pound and Singapore dollar.5 Potentially the set of assets held by the Libra Foundation could include central bank reserves, subject to being allowed to open reserve accounts.
  4. Stablecoins backed by a reserve of cryptocurrencies can be one of the most transparent ways of demonstrating the existence of a reserve. If created correctly holders would be able to check the balances of cryptocurrencies held by addresses relevant to the stablecoin. Unfortunately due the relatively high correlation of all major cryptocurrencies to each other means it is unlikely that the degree of diversification that could be obtained would provide much stability.
  5. Algorithmic stablecoins such as the proposed, “Basis” Coin are intended to be a form of currency that had stable value but which was not fully collateralised. The plan for Basis was for it to be partially collateralised but to use an algorithm to maintain stability by buying or selling the coin in the market. The problem with a “currency” created like this is that it creates the incentive to short the asset, perhaps one of the reasons Basis was abandoned.

It is easy to claim a stablecoin is pegged to the value of an established currency and is backed by reserves is not by itself, it is another matter to maintain a stable value for a stablecoin some of which, such as USDT, experience periods of extreme instability.


Maintaining Stability

Central Banks could potentially issue a form of electronic money that had the same economic characteristics as physical cash or central bank reserves. This is typically referred to as Central Bank Digital Currency (CBDC). CBDC could be issued on some form of DLT (making it a form of stablecoin) or a centralised system. While there have been experiments by central banks with central bank money issued on distributed ledgers, no central bank has announced plans to create a “stablecoin.” The People’s Bank of China has been developing the concept of a form of using digital cash (potentially using DLT) for five years but nothing is in production yet. As of late-2019 the closest thing to a real world CBDC system was Ecuador’s failed attempt, the Dinero Electrónico, which was launched in 2015 and closed in 2018.6

Other relevant issues to maintaining the stability, or even basic credibility of 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. In the USC model, Fnality funds would be set up in a bankruptcy remote structure. 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.

For any stablecoin to remain truly stable it would need an issuer willing to buy and sell the stablecoin at par, or a very small spread above and below par. Even existing stablecoins with better controls that Tether such as Pax or the Gemini Dollar shows significant fluctuations in price. Convertibility on demand causes challenges for stablecoins, it would increase the probability in most jurisdictions that issuers would need to treat the owners of their coins as their customers for AML/KYC purposes. It would also cause challenges in terms of liquidity management. According to the Libra white paper, only specified liquidity providers will be able to buy and sell Libra directly with the Libra foundation. Other holders of Libra will not be able to redeem their Libra directly. JPM Coins will simply be transferred to or from client’s existing J.P. Morgan bank accounts.

Auditing of the reserves and the controls that are put in place to ensure the reserves are segregated from the issuers other liabilities is another fundamental feature required for maintaining price stability against the assets pegged against. One of the major reasons for the volatility of Tether was the lack of a recognised audit of their reserves and the worry, subsequently proved to be correct, that the Tether was not fully backed by reserves held as bank balances.7


Payment and Settlement Processes

For stablecoins to be effective as a part of conventional Financial Market Infrastructure as opposed to just being a tool to support cryptocurrency trading, they need to support the following fundamental processes that involve the transfer of money, either one way movement or synchronised with the movement of money or securities in the other direction.

ProcessDescription
Domestic PaymentsPayments in between two parties in the same jurisdiction in the local currency.
International PaymentsInternational payments typically involve a foreign exchange transaction as the sender’s home currency is converted in the recipient’s home currency. In many cases such as cross-border payments within the Eurozone there may be no need for a foreign exchange transaction.
DVPDelivery versus Payment is the synchronised exchange of a security for cash. DVP is used in both the settlement of purchase/sale of securities and the temporary exchange of cash in securities in areas such as Repo and Securities Lending. In conventional financial markets. Currently DVP requires the use of a trusted third parties such as a Central Securities Depository/Securities Settlement System e.g. DTCC or Euroclear or a custodian.
PVPPayment versus Payment, is the synchronised exchange of two different currencies. PVP is used for the majority of transactions by volume in the foreign exchange payments using the services of CLS Bank.
CustodyHolding a financial asset on behalf of the economic owner of the asset. Custodians provide of a variety of services in addition to basic safe keeping of assets including, lending securities, financing long positions and dealing with corporate actions and events.
CollateralTemporarily delivering financial assets to another party to offset credit risk is fundamental part of the operation of most financial markets. Collateral in the form of money, securities or other financial assets may be delivered to the counterparty, a central bank, a tri-party agent or a CCP depending on the nature of the transaction
NovationNovation is the transfer or contractual obligations and rights from one of the original parties to a contract to another party.

Payments

Domestic payments between customers within the same bank are always the most technically and operationally simple to process. Most banks should have little difficulty in processing payments in anything less than a few seconds and at minimal cost. Fundamentally all users of a particular stablecoin will essentially have an “account” at the same virtual bank, or in the case of JPM Coin or Signet, the same actual bank. Even if a bank has archaic batch-based or even paper-based solutions for internal transfers, using DLT is just one of many possible approaches to speeding up transfers.

Domestic payments between parties that bank use different banks is more considerably more complicated than payments within the same bank because of the need for banks to manage intra-day liquidity in order to avoid running out of the funds required to meet their liabilities.

However huge progress has been made in this area over the last two decades. Payments between parties that bank at different banks has been made close to instant in most developed countries through the implementation of low cost and efficient Real-Time Gross Settlement (RGTS) systems and internationally via initiatives such as SWIFT gpi.

Previously settlement of domestic payments was based on systems that used Deferred Net Settlement (DNS), basically settlement of payments was made at the end of the day after all payment instructions had been received and the net amount each bank owed each other was calculated. The existence of RTGS in over 90 countries has demonstrated that making payments instantly and settling in central bank cash does not remove the problems of liquidity or even credit risk. Central Banks have found the need to implement additional measures to avoid problems resulting from the “lumpy” nature of payments flow between banks, stress conditions and banks passively releasing their own payments after receiving payments from other banks.8

To deal with these issues central banks introduced a variety of mechanisms including Liquidity Savings Mechanisms (LSM), which group together payments before releasing to get smoothing payment flow, targets for the proportion of payments released immediately, and lower fees for the releasing payments earlier during the day. Stablecoins, if they reach sufficient scale, would not get rid of any of these problems and it is likely they would have to replicate the same mechanisms. It is worth noting that as part of its experiment with DLT in domestic payments (Project Ubin) the Monetary Authority of Singapore implemented an LSM using DLT.9

While small scale international payments for many countries can take minutes, wholesale payments can still take days, particularly if they involve the settlement of a related foreign exchange transaction. Based on analysis by SWIFT some of the key sources of delays in international payments include, errors within the systems and processes of both the sending and recipient banks, the need to carry out checks for Anti-Money Laundering (AML) and combatting the financing of terrorism (CFT) and in some countries the operations of exchange controls.

Stablecoins do not innately solve any of these issues, particularly where the desired end result of a payment in a deposit in the bank account of the ultimate recipient in the appropriate currency. More retail-focused stablecoins such as Libra may simplify international payments if Libra is used to directly purchase goods and services. However, holders of Libra (assuming Libra is backed by assets in a basket of currencies) will be exposed to the market risk of fluctuations in exchange rates. It is also unclear what the costs will be on converting into and from Libra.

PVP

The need for payment-versus-payments is an essential need for wholesale FX trading, to avoid settlement or “Herstatt” risk. This is risk that one party to an FX transaction delivers the currency they have sold but the other party does not deliver the currency they are owed, for example due to bankruptcy.

PVP currently requires a trusted third-party to manage cash flows including the release of funds when both parties have delivered the required currency. The majority of foreign exchange transactions are settled through CLS Bank, which provides multilateral netting and connections to the RTGS systems of 17 central banks. On a typical day CLS settles $5 trillion of transactions. The ability to net settlements on a multilateral basis for over 90 of the world’s largest financial institutions allows CLS to reduce the net amount of funds that have to be transferred by 96%.10

The potential opportunity claimed for some stablecoins is the ability to implement a PVP mechanism without the need for having a third party involved and a shorter (if not instant) settlement cycle. The mechanisms required to support PVP using a stablecoin depend on where and how the two currencies are represented. Excluding cryptocurrency related stablecoins such as Tether or Pax, there are the following combinations.

  • Scenario 1 – Currency 1 and Currency 2 are stablecoins created by the same issuer
  • Scenario 2 – Currency 1 and Currency 2 are stablecoins created by different issuers
  • Scenario 3 – Currency 1 is a stablecoin and Currency 2 is a fiat currency

Scenario 1 – USC is currently planned for up to 5 currencies and also plans to have separate ledgers for each currency. Therefore to achieve PVP they would need to create smart contracts that operate on two ledgers simultaneously. Fnality plans to use an architecture called Ion produced by Clearmatics but this is still a work in progress.11 Ion is also planned to support PVP between different ledger technologies such as Ethereum and Hyperledger Fabric.

A more commonly discussed model for dealing with assets on different ledgers, potentially ledgers implemented using different DLT is the “Atomic Swap” where a smart contract on one ledger will only allow the transfer of funds if funds have been transferred on the other ledger:

“Atomic swaps solve this problem through the use of Hash Timelock Contracts (HTLC). As its name denotes, HTLC is a time-bound smart contract between parties that involves the generation of a cryptographic hash function, which can be verified between them. Atomic swaps require both parties to acknowledge receipt of funds within a specified timeframe using a cryptographic hash function. If one of the involved parties fails to confirm the transaction within the timeframe, then the entire transaction is voided, and funds are not exchanged.”12

All the proposed technical models for achieving PVP for ledger-based assets are in the early stages of development. In some proposed stablecoins the degree of centralisation of the stablecoin would make it easier to use an established technology and process design to achieve PVP.

Achieving PVP between a stablecoin and a conventional currency, without involving an intermediary is considerably more problematic. The nature of conventional forms of money mean they are inherently centralised either as a record at a commercial bank or a central bank. Possible models of interaction with existing payment infrastructure is described in the next section “Interaction with Current Financial Market Infrastructure.”

In terms of shortened settlement cycles, stablecoins used for PVP are likely to come into competition with services such as CLS Now, which allows same day settlement of FX transactions using PVP for Canadian dollars, Euros, Pound Sterling and US dollars.

Interest Charges and Payments

It is very easy in a low interest rate environment to forget stablecoins are likely to need some capacity for the payment and collection of interest on balances. This is a particularly strong requirement even now for stablecoins that are proposed to be based by central bank reserves.

For currencies (at time of writing) where the central bank has negative interest rates on balances in reserve accounts (for example the -0.5 % charged by the European Central Bank), it will be necessary to pass on the charge to the holders of stablecoins otherwise the issuer of stablecoins will rapidly become involvement. The issuer of the stablecoins (who holds the backing funds in a reserve account) will need to carefully track who held what balances for what time periods and charge relevant holder, deducting interest owed from balance in the stablecoin or be able to charge interest directly if there are insufficient balances in their stablecoin wallet to pay interest. This inherently introduces and element of credit risk.

Similarly, where a central bank pays interest on reserve accounts it will be necessary for interest to largely be paid on to the relevant stablecoin holder otherwise there is a major disincentive (even at low positive rates) for firms to hold balances in stablecoins for anything other than the shortest possible duration.

DVP

Delivery versus payment is the synchronised exchange of a security for cash. DVP is used in both the settlement of purchase/sale of securities and the temporary exchange of cash in securities in areas such as Repo and Securities Lending. Currently DVP requires the use of a trusted third parties such as a Central Securities Depository (e.g. DTCC or Euroclear or a custodian).

DVP presents many of the same challenges and opportunities as PVP. Three key scenarios would need to be dealt which are similar to the PVP scenarios.

  • Scenario 1 – Stablecoin and securities are both created by the same issuer that contains the same overall network but data is stored on different ledgers
  • Scenario 2 – Stablecoin and securities are recorded on different ledgers run by different organisations and potentially using different forms of DLT.
  • Scenario 3 – Stablecoins would need to be exchanged for securities where ownership is recorded on a central database controlled by a Central Securities Depository or a Share Registrar.

Neither Fnality, JP Morgan, nor Libra have currently announced plans to issue securities on the ledgers they are planning to build to support their stablecoins. This currently leaves only scenarios 2 & 3 as plausible short-term possibilities. Scenario 2 raises the same challenges described for PVP but assumes a significant number of securities would be available as securities that are initially issued as on a distributed ledger or are tokenised versions of conventional securities.

A “tokenised” security is one where the original security is “immobilised” i.e. held in trust by a third party such as custodian and economically and legally equivalent representation of the security is recorded on a Distributed Ledger. There is currently only a small number of securities either issued on distributed ledgers or tokenised. Those that have been issued are typically small scale pilots. Interacting with a CSD to achieve DVP is problematic for the same reasons as trying to achieve PVP between a stablecoin and a conventional asset.

Custody

In the existing financial world, financial assets are held in the name of a third party for a variety of reasons including security and the desire to gain access to the range of service offered by custodians. Custodians provide a range of services that go beyond simply safe keeping of assets. These include operating lending programmes for securities, lending funds against the security of assets held and the processing of corporate actions on securities.

Keeping cryptocurrencies and other crypto-assets with a third party has grown in popularity because of the inherent vulnerability to theft of that most cryptocurrencies and crypto-assets. Obtaining a private key is all that is necessary to transfer all the assets associated with that key.

It is nearly impossible to cancel ore reverse transactions if assets are stolen or even sent to the wrong party by mistake. This is a feature included in cryptocurrencies such as Bitcoin, by design. Reversing transactions in the event of crime or area depends on either law enforcement seizing the private keys or other parties co-operating to return assets (which may have costs) – This is due to lack of central control. Anyone can attempt to “fork” most blockchain based systems but this technical process which basically comes down to re-writing history and pretending certain events did not happen is dependent on the co-operation of a critical mass of infrastructure providers called “miners.” And the loss of the private key means the assets are essentially gone for ever and impossible to retrieve.

Custody of most crypto-assets means handing over the private keys to a third party and attempting to ensure that private key is not used by the third party or their staff to steal. With some custodians, private keys are printed on paper and kept in physical safes. Private keys are broken up into pieces and distributed across multiple systems. In the worst case this simply increases the risk of losing access to the crypto assets.

The need for this form of custody essentially depends on the extent to which a stablecoin is operated on a decentralised ledger. For Libra the extent of decentralisation is currently unclear. For Fnality and JPM Coin the high degree of central issuance makes it unlikely that cryptocurrency type of custody would be required. It is likely that organisations wishing to hold wholesale forms of stablecoins may wish a third party to hold their balances in order to outsource the processing of stablecoin transactions, including payments, receipts and conversion to or from conventional currencies.

Collateral

The final area of processing that stablecoins would need to support is the ability to give or receive them as collateral. Collateral is provided either to a counterparty or trusted third party such as tri-party agent or CCP to offset the credit risk arising from other financial transactions such as derivatives trades. In principal there should be no major issues providing stablecoins as long as the recipient has the technical infrastructure to process stablecoin transactions, value stablecoins and the ability to represent them correctly in systems such as their risk, finance, accounting and operational systems.

Inter-Operating and Competing with Existing Infrastructure

Overview

Stablecoins that are designed to appeal to a wider range of users than cryptocurrencies have to be capable of integration with existing financial market infrastructure. To be accepted by regulators they also need to comply with the appropriate regulations for each jurisdiction. This section describes the types of market infrastructure that will need to be integrated with and the challenges that creates.

The Challenge of Integration

One of the major and inherent weaknesses in the design of cryptocurrencies is the problems that arise when a new form of financial infrastructure is designed without giving any thought to how to integrate with existing infrastructure, whether in terms of market level infrastructure or internal to financial services firms.

The current cryptocurrency industry did not grow to its existing size by operating as a parallel payments and banking system that provides alternative ways to make payments or store value. It grew by throwing away the basic principles of decentralisation and disintermediation by recreating centralised systems (i.e., intermediaries) that kept a parallel record of cryptocurrency holdings to that stored on the ledgers of the relevant cryptocurrency. The repeated hacks, thefts, and other failings consistently demonstrated that this centralised infrastructure to support decentralised assets was seldom built with any regard to meeting the BIS Principles, or even in some cases local laws.13

Challenges to integration largely arise from the factors present in most forms of DLT:

  • Lack of central control over the operation of the system
  • Lack of central control of the deployment of changes to code
  • General inability to stop transactions
  • General inability to reverse transactions
  • Global visibility of all transactions
  • Owners not identifiable
  • Dependence on a cryptocurrency to pay for processing of transactions

Many of these features have been abandoned or worked around as the various forms of DLTs have evolved but to vary degree represent challenges both in terms of integration to FMI and the operation of the key processes related to settlements and payments. Sometimes to the point where it is questionable why a form of DLT makes any sense at call compared to conventional Centralised or Distributed Systems.

Forms of inter-operability

The following are the potential conventional forms of infrastructure that the next generation of proposed stablecoins will would potentially need to interact with.

Strawman

In the following section we focus on the conventional types of financial market infrastructure described below that would be significantly impacted by the more widespread adoption of stablecoins.14

SystemsDescription15
Payment Systems (PS)“A set of instruments, procedures, and rules for the transfer of funds between or among participants; the system includes the participants and the entity operating the arrangement.” This includes the various RTGS.
Central Securities Depositories (CSD)“An entity that provides securities accounts, central safekeeping services, and asset services, which may include the administration of corporate actions and redemptions, and plays an important role in helping to ensure the integrity of securities issues (that is, ensure that securities are not accidentally or fraudulently created or destroyed or their details changed).”
Securities Settlement Systems (SSS)“An entity that enables securities to be transferred and settled by book entry according to a set of predetermined multilateral rules. Such systems allow transfers of securities either free of payment or against payment.”
Central Counterparties (CCP)“An entity that interposes itself between counterparties to contracts traded in one or more financial markets, becoming the buyer to every seller and the seller to every buyer and thereby ensuring the performance of open contracts.”
CLS“CLS Bank (CLS) is a limited purpose bank for settling FX, based in New York with its main operations in London. It is owned by 69 financial institutions which are significant players in the FX market. It currently settles trades in 17 currencies. CLS removes principal risk by using PVP – you get paid only if you pay. On settlement day, each counterparty to the trade pays to CLS the currency it is selling – eg by using a correspondent bank, as with the example in the previous box. However, unlike the previous example, CLS pays out the bought currency only if the sold currency is received. In effect, CLS acts as a trusted third party in the settlement process.”16
Internal Financial System InfrastructureThe core internal infrastructure of banks and financial institutions. This includes systems used for risk management, P&L calculation, transaction execution and accounting

Payment Systems (PS)

Stablecoins that are backed (in whole or in part) by bank balances at commercial or central banks will need some degree of integration with a payments system or the payments infrastructure of a given bank. This will be necessary to process the receipt of funds that preceded the issuance of new coins, outgoing payments when there is a redemption and potentially payments or receipts of interest on stablecoin balances. A stablecoin based on central bank reserves would generally need to be connected to some of Real-Time Gross Settlement system to minimise delays in the issuance of new coins.

Such integration is generally straightforward assuming the issuer of stablecoins is allowed to access directly relevant payment systems.  A more interesting question is the impact of stablecoins as a competitor to conventional payment systems.

A stablecoin denominated in a single currency needs to demonstrate it has some form of superiority in terms one or more of the following

  • Transaction Speed
  • Transaction Cost
  • Reduced Operational Risk
  • Ability make payment conditional on other parts of a financial transaction (as in the case of PVP, DVP etc.)

While at the same time dealing with the challenges of ensuring there is sufficient liquidity in the stablecoin network for parties to meet their obligations. The experience of introducing RTGS in over 90 central banks since 1980s demonstrated that allowing a pure system of gross settlements in payments, with participants free to release payments at any time can cause liquidity issues that need to be dealt with by technical changes, such as the implementation of Liquidity Saving Mechanisms (LSM).17

To quote the New York Fed:

“Liquidity-saving mechanisms (LSMs) are queuing arrangements for payments that operate alongside traditional real-time gross settlement (RTGS) systems. LSMs allow banks to condition the release of queued payments on the receipt of offsetting or partially offsetting payments;”18

Some central banks also created rules/targets for when payments should be released or financial incentives for early release of payments.

Retail focused stablecoins need to be able compete with faster payments, credit card and debit card networks. Payments mechanisms that can be highly efficient in many economies. In cross-border payments, stablecoins need to be able to demonstrate they are a more efficient mechanism for dealing with the major areas of delays and costs such as compliance with AML rules and in some markets exchange controls.

Central Securities Depositories & Securities Settlement Systems

For infrastructure such as Euroclear, DTCC, ASX’s CHESS system or Takasbank in Turkey to perform delivery versus payment, they need to have access to a security register to update ownership records and a funds belonging to participants, either held directly at the FMI or at a Central Bank. They also need to be able to provide trade capture, matching and netting capabilities.

For a stablecoin to be used in the DVP settlement, the FMI needs to be able to directly access stablecoin balances belonging to the participants in trades, either directly or on behalf of participants by a third party. This would require work by both the CSD/SSS and the stablecoin provider. There is no obvious benefit from this arrangement. Other systems belonging to the CSD/SSS would need to be modified to represent what is effectively a new currency. For countries that have long established infrastructure in this area, it quite likely adding an additional currency would require additional effort.

Central Counterparties (CCP)

Any organisation likely to acquire large balances in high quality stablecoins is likely to want to be able to provide those stablecoins as collateral in bilateral transactions, with central banks and with Central Counterparties. Should CCPs chose to accept stablecoins they would need to make significant changes to their systems to interact with the relevant distributed ledgers and set them up as new currencies or asset classes within their systems.

CLS

CLS is such a fundamental part of the global financial market infrastructure that any stablecoin that is used on a very large scale is likely to need some degree of integration. It should be remembered though that the vast majority of currencies (by number not importance) are not supported by CLS. Potentially a stablecoin could be added as another CLS currency allowing the benefits of multilateral netting and integration into the core global FX processing. However it would depend on a very high degree of demand and a many regulatory approvals.

In many ways stablecoins compete directly with existing CLS services so it is also questionable the extent to which CLS may support their adoption.

Interoperability with Financial Sector Internal Systems

There are two main areas where the internal systems of financial sector firms would require modification. Their outward facing interfaces that would need to interact with a range of distributed ledgers (unless they outsource this interaction to third parties – essentially creating a new class of correspondent bank) and modifications to inward facing systems such as those belonging to the risk, finance, trading, operations and treasury departments. Perhaps the closet analogy was the creation of an offshore version of the Chinese Yuan, commonly known as “CNH.” Though no wholescale re-engineering was required, it did commonly require changes to be made across a great many systems to recognise the difference between CNH and the on-shore version of the Yuan, “CNY.” This had a particularly large impact for those banks offering services in CNH.

Having two versions (or more) of essentially the same currency creates a great deal of scope for confusion in trading, treasury and support processes. Subtle differences in liquidity and conversion costs also mean that the different versions of the same currency have to be treated differently in many different ways including charges, interest rates and the curves used in pricing positions.

Interoperability with Distributed Ledger Based Infrastructure

Interoperability with emerging infrastructure based on DLT is also likely to create a number of challenges.

Some forms of Market Infrastructure in-progress (or beta) such as ASX’s CHESS system (for securities settlement) and the HQLA-X system for exchange of High-Quality Liquid Assets for lower grade assets are essentially centralised systems that use elements of DLT as part of the overall system design. Interfaces would need to be like any other form of FMI. Those interfaces would need to take into consideration security, privacy and the need for agreed data standards. There would also be the complications of adding what is effectively a new currency.

One of the proposed methods of allowing interaction between different types of ledger or even different instances of the same DLT but recording different assets or used by different parties, is the Atomic Swap. Using this method, funds on the two different ledgers are only released when both parties acknowledge that assets have been transferred. If the two acknowledgements are not received within the agreed time, the assets will be transferred back to the original addresses.

Atomic Swaps are still an emerging technology that have been widely tested in cryptocurrencies. However on a theoretical level they raise governance issues. If assets are on ledgers ultimately controlled by two different parties, whose has governance over the transaction? It also provides an element of optionality to each party to change their mind about whether to go ahead with the transaction. They could simply not deliver and have their asset returned to them. There are similar problems in the current world. Some counterparties have high rates of settlement failure on securities related trades because of issues in their operational processes or systems. Others at times have financial incentives to allow trades to fail, which had created significant problems in the operation of the Repo market.19 This has resulted in stricter rules and fines in many jurisdictions.

Conclusions

Creating stablecoins as forms of either financial market infrastructure (i.e. used by multiple financial bodies in the case of USC or as essentially internal systems, as is in the case of JPM Coin, Wells Fargo Digital Cash or Signet) clearly does not require the use of any form of Distributed Ledger Technology. Most of the use cases ultimately involve some form of book transfer of funds within essentially the same systems. Allowing customers of the same bank to transfer funds between each other in real-time 24*7 at little to no cost is a service provided by many banks today. The only bottleneck to allowing this in other banks is either a lack of willingness to provide the service or the use of antiquated systems that rely on batch processing.

Liquidity issues out of hours

At the market level, real-time payments within a currency bloc, that settle in central bank money have been implemented using Real-Time Gross Settlement Systems in over 90 countries to date. Some of those payments systems such as the Eurosystem’s TARGET2 have been extended to support securities settlement (T2S) and smaller scale instant payments (TIPS). For the cross-border market CLS connects together the RTGS of 17 currencies to allow PVP settlement against central bank reserves.

The challenges faced in creating creditable stablecoins that can grow beyond simply supporting speculation in cryptocurrency trading are large. Stablecoins backed by Central Bank reserves require the explicit backing of the relevant central banks. Stablecoins such as Libra have attracted extreme scrutiny if not outright opposition from Central Banks and politicians both because of concerns over the stability of the financial system and a lack of trust by some politicians in Facebook as an organisation. Any stablecoin that is regarded as a key part of Financial Market Infrastructure is likely to be required to meet strict regulatory controls, reflecting the principles laid out by the BIS in “Principles for financial market infrastructures.”

Creating interoperability between the infrastructure on which stablecoins operate and existing infrastructure, not to mention potential future infrastructure that runs on different versions of DLT is a non-trivial task, not made any easier by the use of DLT. Such interoperability will be vital if stablecoins ever hope to be anything more than parallel RTGS systems.

Finally the obstacles that have been encountered by RTGS in managing liquidity are unlike to be removed by the use of DLT. In many countries the introduction of RTGS, identified the need to create mechanisms to ensure firms did not hold back payments, creating intra-day funding needs, intra-day credit risk and general systemic risk. If is very likely that if stablecoins were used in a significant volume of transactions there would be a need to introduce many of those measure described that had to introduced for RTGS such as Liquidity Savings Mechanisms.

Then there are the challenges with DLT. None of the various forms of DLT have proven themselves at scale and in a regulated environment and it is questionable whether they a better form of technology, even for implementing stablecoins that existing technologies.

Stablecoins may succeed in the long-run if they can demonstrate an ability to support better ways to manage liquidity including broader, if not continuous, settlement cycles for both money and securities. Finally one of the key concepts between more advanced forms of DLT such as Ethereum or Fabric was to allow parties to agree bilaterally or in groups to deploy agreed business logic in the form of “Smart Contracts” that can be executed when transactions are processed. This type of flexibility could be a potential path to the a higher degree of standardisation in processing financial transactions without the need to have a central, and inherently slow moving body, setting standards for a whole area of business or jurisdiction.


References

  1. Financial TimesFacebook’s Libra currency draws instant response from regulators” 18th June 2019 []
  2. Investigating the impact of global stablecoins” by G7, IMF, and BIS []
  3. As it is for state-issued currencies. The RTGS Dollar in Zimbabwe was pegged in value to the U.S. dollar but lacked sufficient reserves causing it to crumble in the face of market forces. []
  4. Tether (the company) changed its statements about the backing of Tether the current early in 2019. []
  5. Libra whitepaper []
  6. The World’s First Central Bank Electronic Money Has Come – And Gone: Ecuador, 2014-2018 from Seeking Alpha []
  7. Tether Lawyer Admits Stablecoin Now 74% Backed by Cash and Equivalents from Coindesk []
  8. Liquidity Saving in Real-Time Gross Settlement Systems – An Overview from B. Norman []
  9. Project Ubin: Central Bank Digital Money using Distributed Ledger Technology from MAS []
  10. CLSSettlement []
  11. Ion: The Vision []
  12. Atomic Swaps Defined []
  13. Principles for financial market infrastructures – from CPMI and IOSCO []
  14. The complete list of FMI’s listed by the Bank for International Settlement includes Trade Depositories  – “an entity that maintains a centralised electronic record (database) of transaction data” []
  15. Definitions/Descriptions quoted from BIS “Principles for financial market infrastructures” and BIS Quarterly Review, September 2008 []
  16. Extract from page 57 of BIS Quarterly Review, September 2008 []
  17. How has the Liquidity Saving Mechanism reduced banks’ intraday liquidity costs in CHAPS? from Quarterly Bulletin []
  18. An Economic Analysis of Liquidity-Saving Mechanisms from Martin and McAndrews []
  19. Why $200bn in US trades are failing each day from Financial Times []