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Summary: Everyone knows that when you give your assets to someone else, they always keep them safe. If this is true for individuals, it is certainly true for businesses. Custodians always tell the truth and manage funds properly. They won't have any interest in taking the assets as an exchange operator would. Auditors tell the truth and can't be misled. That's because organizations that are regulated are incapable of lying and don't make mistakes. First, some background. Here is a summary of how custodians make us more secure: Previously, we might give Alice our crypto assets to hold. There were risks:
Alice might take the assets and disappear.
Alice might spend the assets and pretend that she still has them (fractional model).
Alice might store the assets insecurely and they'll get stolen.
Alice might give the assets to someone else by mistake or by force.
Alice might lose access to the assets.
But "no worries", Alice has a custodian named Bob. Bob is dressed in a nice suit. He knows some politicians. And he drives a Porsche. "So you have nothing to worry about!". And look at all the benefits we get:
Alice can't take the assets and disappear (unless she asks Bob or never gives them to Bob).
Alice can't spend the assets and pretend that she still has them. (Unless she didn't give them to Bob or asks him for them.)
Alice can't store the assets insecurely so they get stolen. (After all - she doesn't have any control over the withdrawal process from any of Bob's systems, right?)
Alice can't give the assets to someone else by mistake or by force. (Bob will stop her, right Bob?)
Alice can't lose access to the funds. (She'll always be present, sane, and remember all secrets, right?)
See - all problems are solved! All we have to worry about now is:
Bob might take the assets and disappear.
Bob might spend the assets and pretend that he still has them (fractional model).
Bob might store the assets insecurely and they'll get stolen.
Bob might give the assets to someone else by mistake or by force.
Bob might lose access to the assets.
It's pretty simple. Before we had to trust Alice. Now we only have to trust Alice, Bob, and all the ways in which they communicate. Just think of how much more secure we are! "On top of that", Bob assures us, "we're using a special wallet structure". Bob shows Alice a diagram. "We've broken the balance up and store it in lots of smaller wallets. That way", he assures her, "a thief can't take it all at once". And he points to a historic case where a large sum was taken "because it was stored in a single wallet... how stupid". "Very early on, we used to have all the crypto in one wallet", he said, "and then one Christmas a hacker came and took it all. We call him the Grinch. Now we individually wrap each crypto and stick it under a binary search tree. The Grinch has never been back since." "As well", Bob continues, "even if someone were to get in, we've got insurance. It covers all thefts and even coercion, collusion, and misplaced keys - only subject to the policy terms and conditions." And with that, he pulls out a phone-book sized contract and slams it on the desk with a thud. "Yep", he continues, "we're paying top dollar for one of the best policies in the country!" "Can I read it?' Alice asks. "Sure," Bob says, "just as soon as our legal team is done with it. They're almost through the first chapter." He pauses, then continues. "And can you believe that sales guy Mike? He has the same year Porsche as me. I mean, what are the odds?" "Do you use multi-sig?", Alice asks. "Absolutely!" Bob replies. "All our engineers are fully trained in multi-sig. Whenever we want to set up a new wallet, we generate 2 separate keys in an air-gapped process and store them in this proprietary system here. Look, it even requires the biometric signature from one of our team members to initiate any withdrawal." He demonstrates by pressing his thumb into the display. "We use a third-party cloud validation API to match the thumbprint and authorize each withdrawal. The keys are also backed up daily to an off-site third-party." "Wow that's really impressive," Alice says, "but what if we need access for a withdrawal outside of office hours?" "Well that's no issue", Bob says, "just send us an email, call, or text message and we always have someone on staff to help out. Just another part of our strong commitment to all our customers!" "What about Proof of Reserve?", Alice asks. "Of course", Bob replies, "though rather than publish any blockchain addresses or signed transaction, for privacy we just do a SHA256 refactoring of the inverse hash modulus for each UTXO nonce and combine the smart contract coefficient consensus in our hyperledger lightning node. But it's really simple to use." He pushes a button and a large green checkmark appears on a screen. "See - the algorithm ran through and reserves are proven." "Wow", Alice says, "you really know your stuff! And that is easy to use! What about fiat balances?" "Yeah, we have an auditor too", Bob replies, "Been using him for a long time so we have quite a strong relationship going! We have special books we give him every year and he's very efficient! Checks the fiat, crypto, and everything all at once!" "We used to have a nice offline multi-sig setup we've been using without issue for the past 5 years, but I think we'll move all our funds over to your facility," Alice says. "Awesome", Bob replies, "Thanks so much! This is perfect timing too - my Porsche got a dent on it this morning. We have the paperwork right over here." "Great!", Alice replies. And with that, Alice gets out her pen and Bob gets the contract. "Don't worry", he says, "you can take your crypto-assets back anytime you like - just subject to our cancellation policy. Our annual management fees are also super low and we don't adjust them often". How many holes have to exist for your funds to get stolen? Just one. Why are we taking a powerful offline multi-sig setup, widely used globally in hundreds of different/lacking regulatory environments with 0 breaches to date, and circumventing it by a demonstrably weak third party layer? And paying a great expense to do so? If you go through the list of breaches in the past 2 years to highly credible organizations, you go through the list of major corporate frauds (only the ones we know about), you go through the list of all the times platforms have lost funds, you go through the list of times and ways that people have lost their crypto from identity theft, hot wallet exploits, extortion, etc... and then you go through this custodian with a fine-tooth comb and truly believe they have value to add far beyond what you could, sticking your funds in a wallet (or set of wallets) they control exclusively is the absolute worst possible way to take advantage of that security. The best way to add security for crypto-assets is to make a stronger multi-sig. With one custodian, what you are doing is giving them your cryptocurrency and hoping they're honest, competent, and flawlessly secure. It's no different than storing it on a really secure exchange. Maybe the insurance will cover you. Didn't work for Bitpay in 2015. Didn't work for Yapizon in 2017. Insurance has never paid a claim in the entire history of cryptocurrency. But maybe you'll get lucky. Maybe your exact scenario will buck the trend and be what they're willing to cover. After the large deductible and hopefully without a long and expensive court battle. And you want to advertise this increase in risk, the lapse of judgement, an accident waiting to happen, as though it's some kind of benefit to customers ("Free institutional-grade storage for your digital assets.")? And then some people are writing to the OSC that custodians should be mandatory for all funds on every exchange platform? That this somehow will make Canadians as a whole more secure or better protected compared with standard air-gapped multi-sig? On what planet? Most of the problems in Canada stemmed from one thing - a lack of transparency. If Canadians had known what a joke Quadriga was - it wouldn't have grown to lose $400m from hard-working Canadians from coast to coast to coast. And Gerald Cotten would be in jail, not wherever he is now (at best, rotting peacefully). EZ-BTC and mister Dave Smilie would have been a tiny little scam to his friends, not a multi-million dollar fraud. Einstein would have got their act together or been shut down BEFORE losing millions and millions more in people's funds generously donated to criminals. MapleChange wouldn't have even been a thing. And maybe we'd know a little more about CoinTradeNewNote - like how much was lost in there. Almost all of the major losses with cryptocurrency exchanges involve deception with unbacked funds. So it's great to see transparency reports from BitBuy and ShakePay where someone independently verified the backing. The only thing we don't have is:
ANY CERTAINTY BALANCES WEREN'T EXCLUDED. Quadriga's largest account was $70m. 80% of funds are in 20% of accounts (Pareto principle). All it takes is excluding a few really large accounts - and nobody's the wiser. A fractional platform can easily pass any audit this way.
ANY VISIBILITY WHATSOEVER INTO THE CUSTODIANS. BitBuy put out their report before moving all the funds to their custodian and ShakePay apparently can't even tell us who the custodian is. That's pretty important considering that basically all of the funds are now stored there.
ANY IDEA ABOUT THE OTHER EXCHANGES. In order for this to be effective, it has to be the norm. It needs to be "unusual" not to know. If obscurity is the norm, then it's super easy for people like Gerald Cotten and Dave Smilie to blend right in.
It's not complicated to validate cryptocurrency assets. They need to exist, they need to be spendable, and they need to cover the total balances. There are plenty of credible people and firms across the country that have the capacity to reasonably perform this validation. Having more frequent checks by different, independent, parties who publish transparent reports is far more valuable than an annual check by a single "more credible/official" party who does the exact same basic checks and may or may not publish anything. Here's an example set of requirements that could be mandated:
First report within 1 month of launching, another within 3 months, and further reports at minimum every 6 months thereafter.
No auditor can be repeated within a 12 month period.
All reports must be public, identifying the auditor and the full methodology used.
All auditors must be independent of the firm being audited with no conflict of interest.
Reports must include the percentage of each asset backed, and how it's backed.
The auditor publishes a hash list, which lists a hash of each customer's information and balances that were included. Hash is one-way encryption so privacy is fully preserved. Every customer can use this to have 100% confidence they were included.
If we want more extensive requirements on audits, these should scale upward based on the total assets at risk on the platform, and whether the platform has loaned their assets out.
There are ways to structure audits such that neither crypto assets nor customer information are ever put at risk, and both can still be properly validated and publicly verifiable. There are also ways to structure audits such that they are completely reasonable for small platforms and don't inhibit innovation in any way. By making the process as reasonable as possible, we can completely eliminate any reason/excuse that an honest platform would have for not being audited. That is arguable far more important than any incremental improvement we might get from mandating "the best of the best" accountants. Right now we have nothing mandated and tons of Canadians using offshore exchanges with no oversight whatsoever. Transparency does not prove crypto assets are safe. CoinTradeNewNote, Flexcoin ($600k), and Canadian Bitcoins ($100k) are examples where crypto-assets were breached from platforms in Canada. All of them were online wallets and used no multi-sig as far as any records show. This is consistent with what we see globally - air-gapped multi-sig wallets have an impeccable record, while other schemes tend to suffer breach after breach. We don't actually know how much CoinTrader lost because there was no visibility. Rather than publishing details of what happened, the co-founder of CoinTrader silently moved on to found another platform - the "most trusted way to buy and sell crypto" - a site that has no information whatsoever (that I could find) on the storage practices and a FAQ advising that “[t]rading cryptocurrency is completely safe” and that having your own wallet is “entirely up to you! You can certainly keep cryptocurrency, or fiat, or both, on the app.” Doesn't sound like much was learned here, which is really sad to see. It's not that complicated or unreasonable to set up a proper hardware wallet. Multi-sig can be learned in a single course. Something the equivalent complexity of a driver's license test could prevent all the cold storage exploits we've seen to date - even globally. Platform operators have a key advantage in detecting and preventing fraud - they know their customers far better than any custodian ever would. The best job that custodians can do is to find high integrity individuals and train them to form even better wallet signatories. Rather than mandating that all platforms expose themselves to arbitrary third party risks, regulations should center around ensuring that all signatories are background-checked, properly trained, and using proper procedures. We also need to make sure that signatories are empowered with rights and responsibilities to reject and report fraud. They need to know that they can safely challenge and delay a transaction - even if it turns out they made a mistake. We need to have an environment where mistakes are brought to the surface and dealt with. Not one where firms and people feel the need to hide what happened. In addition to a knowledge-based test, an auditor can privately interview each signatory to make sure they're not in coercive situations, and we should make sure they can freely and anonymously report any issues without threat of retaliation. A proper multi-sig has each signature held by a separate person and is governed by policies and mutual decisions instead of a hierarchy. It includes at least one redundant signature. For best results, 3of4, 3of5, 3of6, 4of5, 4of6, 4of7, 5of6, or 5of7. History has demonstrated over and over again the risk of hot wallets even to highly credible organizations. Nonetheless, many platforms have hot wallets for convenience. While such losses are generally compensated by platforms without issue (for example Poloniex, Bitstamp, Bitfinex, Gatecoin, Coincheck, Bithumb, Zaif, CoinBene, Binance, Bitrue, Bitpoint, Upbit, VinDAX, and now KuCoin), the public tends to focus more on cases that didn't end well. Regardless of what systems are employed, there is always some level of risk. For that reason, most members of the public would prefer to see third party insurance. Rather than trying to convince third party profit-seekers to provide comprehensive insurance and then relying on an expensive and slow legal system to enforce against whatever legal loopholes they manage to find each and every time something goes wrong, insurance could be run through multiple exchange operators and regulators, with the shared interest of having a reputable industry, keeping costs down, and taking care of Canadians. For example, a 4 of 7 multi-sig insurance fund held between 5 independent exchange operators and 2 regulatory bodies. All Canadian exchanges could pay premiums at a set rate based on their needed coverage, with a higher price paid for hot wallet coverage (anything not an air-gapped multi-sig cold wallet). Such a model would be much cheaper to manage, offer better coverage, and be much more reliable to payout when needed. The kind of coverage you could have under this model is unheard of. You could even create something like the CDIC to protect Canadians who get their trading accounts hacked if they can sufficiently prove the loss is legitimate. In cases of fraud, gross negligence, or insolvency, the fund can be used to pay affected users directly (utilizing the last transparent balance report in the worst case), something which private insurance would never touch. While it's recommended to have official policies for coverage, a model where members vote would fully cover edge cases. (Could be similar to the Supreme Court where justices vote based on case law.) Such a model could fully protect all Canadians across all platforms. You can have a fiat coverage governed by legal agreements, and crypto-asset coverage governed by both multi-sig and legal agreements. It could be practical, affordable, and inclusive. Now, we are at a crossroads. We can happily give up our freedom, our innovation, and our money. We can pay hefty expenses to auditors, lawyers, and regulators year after year (and make no mistake - this cost will grow to many millions or even billions as the industry grows - and it will be borne by all Canadians on every platform because platforms are not going to eat up these costs at a loss). We can make it nearly impossible for any new platform to enter the marketplace, forcing Canadians to use the same stagnant platforms year after year. We can centralize and consolidate the entire industry into 2 or 3 big players and have everyone else fail (possibly to heavy losses of users of those platforms). And when a flawed security model doesn't work and gets breached, we can make it even more complicated with even more people in suits making big money doing the job that blockchain was supposed to do in the first place. We can build a system which is so intertwined and dependent on big government, traditional finance, and central bankers that it's future depends entirely on that of the fiat system, of fractional banking, and of government bail-outs. If we choose this path, as history has shown us over and over again, we can not go back, save for revolution. Our children and grandchildren will still be paying the consequences of what we decided today. Or, we can find solutions that work. We can maintain an open and innovative environment while making the adjustments we need to make to fully protect Canadian investors and cryptocurrency users, giving easy and affordable access to cryptocurrency for all Canadians on the platform of their choice, and creating an environment in which entrepreneurs and problem solvers can bring those solutions forward easily. None of the above precludes innovation in any way, or adds any unreasonable cost - and these three policies would demonstrably eliminate or resolve all 109 historic cases as studied here - that's every single case researched so far going back to 2011. It includes every loss that was studied so far not just in Canada but globally as well. Unfortunately, finding answers is the least challenging part. Far more challenging is to get platform operators and regulators to agree on anything. My last post got no response whatsoever, and while the OSC has told me they're happy for industry feedback, I believe my opinion alone is fairly meaningless. This takes the whole community working together to solve. So please let me know your thoughts. Please take the time to upvote and share this with people. Please - let's get this solved and not leave it up to other people to do. Facts/background/sources (skip if you like):
The inspiration for the paragraph about splitting wallets was an actual quote from a Canadian company providing custodial services in response to the OSC consultation paper: "We believe that it will be in the in best interests of investors to prohibit pooled crypto assets or ‘floats’. Most Platforms pool assets, citing reasons of practicality and expense. The recent hack of the world’s largest Platform – Binance – demonstrates the vulnerability of participants’ assets when such concessions are made. In this instance, the Platform’s entire hot wallet of Bitcoins, worth over $40 million, was stolen, facilitated in part by the pooling of client crypto assets." "the maintenance of participants (and Platform) crypto assets across multiple wallets distributes the related risk and responsibility of security - reducing the amount of insurance coverage required and making insurance coverage more readily obtainable". For the record, their reply also said nothing whatsoever about multi-sig or offline storage.
In addition to the fact that the $40m hack represented only one "hot wallet" of Binance, and they actually had the vast majority of assets in other wallets (including mostly cold wallets), multiple real cases have clearly demonstrated that risk is still present with multiple wallets. Bitfinex, VinDAX, Bithumb, Altsbit, BitPoint, Cryptopia, and just recently KuCoin all had multiple wallets breached all at the same time, and may represent a significantly larger impact on customers than the Binance breach which was fully covered by Binance. To represent that simply having multiple separate wallets under the same security scheme is a comprehensive way to reduce risk is just not true.
Private insurance has historically never covered a single loss in the cryptocurrency space (at least, not one that I was able to find), and there are notable cases where massive losses were not covered by insurance. Bitpay in 2015 and Yapizon in 2017 both had insurance policies that didn't pay out during the breach, even after a lengthly court process. The same insurance that ShakePay is presently using (and announced to much fanfare) was describe by their CEO himself as covering “physical theft of the media where the private keys are held,” which is something that has never historically happened. As was said with regard to the same policy in 2018 - “I don’t find it surprising that Lloyd’s is in this space,” said Johnson, adding that to his mind the challenge for everybody is figuring out how to structure these policies so that they are actually protective. “You can create an insurance policy that protects no one – you know there are so many caveats to the policy that it’s not super protective.”
The most profitable policy for a private insurance company is one with the most expensive premiums that they never have to pay a claim on. They have no inherent incentive to take care of people who lost funds. It's "cheaper" to take the reputational hit and fight the claim in court. The more money at stake, the more the insurance provider is incentivized to avoid payout. They're not going to insure the assets unless they have reasonable certainty to make a profit by doing so, and they're not going to pay out a massive sum unless it's legally forced. Private insurance is always structured to be maximally profitable to the insurance provider.
The circumvention of multi-sig was a key factor in the massive Bitfinex hack of over $60m of bitcoin, which today still sits being slowly used and is worth over $3b. While Bitfinex used a qualified custodian Bitgo, which was and still is active and one of the industry leaders of custodians, and they set up 2 of 3 multi-sig wallets, the entire system was routed through Bitfinex, such that Bitfinex customers could initiate the withdrawals in a "hot" fashion. This feature was also a hit with the hacker. The multi-sig was fully circumvented.
Bitpay in 2015 was another example of a breach that stole 5,000 bitcoins. This happened not through the exploit of any system in Bitpay, but because the CEO of a company they worked with got their computer hacked and the hackers were able to request multiple bitcoin purchases, which Bitpay honoured because they came from the customer's computer legitimately. Impersonation is a very common tactic used by fraudsters, and methods get more extreme all the time.
A notable case in Canada was the Canadian Bitcoins exploit. Funds were stored on a server in a Rogers Data Center, and the attendee was successfully convinced to reboot the server "in safe mode" with a simple phone call, thus bypassing the extensive security and enabling the theft.
The very nature of custodians circumvents multi-sig. This is because custodians are not just having to secure the assets against some sort of physical breach but against any form of social engineering, modification of orders, fraudulent withdrawal attempts, etc... If the security practices of signatories in a multi-sig arrangement are such that the breach risk of one signatory is 1 in 100, the requirement of 3 independent signatures makes the risk of theft 1 in 1,000,000. Since hackers tend to exploit the weakest link, a comparable custodian has to make the entry and exit points of their platform 10,000 times more secure than one of those signatories to provide equivalent protection. And if the signatories beef up their security by only 10x, the risk is now 1 in 1,000,000,000. The custodian has to be 1,000,000 times more secure. The larger and more complex a system is, the more potential vulnerabilities exist in it, and the fewer people can understand how the system works when performing upgrades. Even if a system is completely secure today, one has to also consider how that system might evolve over time or work with different members.
By contrast, offline multi-signature solutions have an extremely solid record, and in the entire history of cryptocurrency exchange incidents which I've studied (listed here), there has only been one incident (796 exchange in 2015) involving an offline multi-signature wallet. It happened because the customer's bitcoin address was modified by hackers, and the amount that was stolen ($230k) was immediately covered by the exchange operators. Basically, the platform operators were tricked into sending a legitimate withdrawal request to the wrong address because hackers exploited their platform to change that address. Such an issue would not be prevented in any way by the use of a custodian, as that custodian has no oversight whatsoever to the exchange platform. It's practical for all exchange operators to test large withdrawal transactions as a general policy, regardless of what model is used, and general best practice is to diagnose and fix such an exploit as soon as it occurs.
False promises on the backing of funds played a huge role in the downfall of Quadriga, and it's been exposed over and over again (MyCoin, PlusToken, Bitsane, Bitmarket, EZBTC, IDAX). Even today, customers have extremely limited certainty on whether their funds in exchanges are actually being backed or how they're being backed. While this issue is not unique to cryptocurrency exchanges, the complexity of the technology and the lack of any regulation or standards makes problems more widespread, and there is no "central bank" to come to the rescue as in the 2008 financial crisis or during the great depression when "9,000 banks failed".
In addition to fraudulent operations, the industry is full of cases where operators have suffered breaches and not reported them. Most recently, Einstein was the largest case in Canada, where ongoing breaches and fraud were perpetrated against the platform for multiple years and nobody found out until the platform collapsed completely. While fraud and breaches suck to deal with, they suck even more when not dealt with. Lack of visibility played a role in the largest downfalls of Mt. Gox, Cryptsy, and Bitgrail. In some cases, platforms are alleged to have suffered a hack and keep operating without admitting it at all, such as CoinBene.
It surprises some to learn that a cryptographic solution has already existed since 2013, and gained widespread support in 2014 after Mt. Gox. Proof of Reserves is a full cryptographic proof that allows any customer using an exchange to have complete certainty that their crypto-assets are fully backed by the platform in real-time. This is accomplished by proving that assets exist on the blockchain, are spendable, and fully cover customer deposits. It does not prove safety of assets or backing of fiat assets.
If we didn't care about privacy at all, a platform could publish their wallet addresses, sign a partial transaction, and put the full list of customer information and balances out publicly. Customers can each check that they are on the list, that the balances are accurate, that the total adds up, and that it's backed and spendable on the blockchain. Platforms who exclude any customer take a risk because that customer can easily check and see they were excluded. So together with all customers checking, this forms a full proof of backing of all crypto assets.
However, obviously customers care about their private information being published. Therefore, a hash of the information can be provided instead. Hash is one-way encryption. The hash allows the customer to validate inclusion (by hashing their own known information), while anyone looking at the list of hashes cannot determine the private information of any other user. All other parts of the scheme remain fully intact. A model like this is in use on the exchange CoinFloor in the UK.
A Merkle tree can provide even greater privacy. Instead of a list of balances, the balances are arranged into a binary tree. A customer starts from their node, and works their way to the top of the tree. For example, they know they have 5 BTC, they plus 1 other customer hold 7 BTC, they plus 2-3 other customers hold 17 BTC, etc... until they reach the root where all the BTC are represented. Thus, there is no way to find the balances of other individual customers aside from one unidentified customer in this case.
Proposals such as this had the backing of leaders in the community including Nic Carter, Greg Maxwell, and Zak Wilcox. Substantial and significant effort started back in 2013, with massive popularity in 2014. But what became of that effort? Very little. Exchange operators continue to refuse to give visibility. Despite the fact this information can often be obtained through trivial blockchain analysis, no Canadian platform has ever provided any wallet addresses publicly. As described by the CEO of Newton "For us to implement some kind of realtime Proof of Reserves solution, which I'm not opposed to, it would have to ... Preserve our users' privacy, as well as our own. Some kind of zero-knowledge proof". Kraken describes here in more detail why they haven't implemented such a scheme. According to professor Eli Ben-Sasson, when he spoke with exchanges, none were interested in implementing Proof of Reserves.
And yet, Kraken's places their reasoning on a page called "Proof of Reserves". More recently, both BitBuy and ShakePay have released reports titled "Proof of Reserves and Security Audit". Both reports contain disclaimers against being audits. Both reports trust the customer list provided by the platform, leaving the open possibility that multiple large accounts could have been excluded from the process. Proof of Reserves is a blockchain validation where customers see the wallets on the blockchain. The report from Kraken is 5 years old, but they leave it described as though it was just done a few weeks ago. And look at what they expect customers to do for validation. When firms represent something being "Proof of Reserve" when it's not, this is like a farmer growing fruit with pesticides and selling it in a farmers market as organic produce - except that these are people's hard-earned life savings at risk here. Platforms are misrepresenting the level of visibility in place and deceiving the public by their misuse of this term. They haven't proven anything.
Fraud isn't a problem that is unique to cryptocurrency. Fraud happens all the time. Enron, WorldCom, Nortel, Bear Stearns, Wells Fargo, Moser Baer, Wirecard, Bre-X, and Nicola are just some of the cases where frauds became large enough to become a big deal (and there are so many countless others). These all happened on 100% reversible assets despite regulations being in place. In many of these cases, the problems happened due to the over-complexity of the financial instruments. For example, Enron had "complex financial statements [which] were confusing to shareholders and analysts", creating "off-balance-sheet vehicles, complex financing structures, and deals so bewildering that few people could understand them". In cryptocurrency, we are often combining complex financial products with complex technologies and verification processes. We are naïve if we think problems like this won't happen. It is awkward and uncomfortable for many people to admit that they don't know how something works. If we want "money of the people" to work, the solutions have to be simple enough that "the people" can understand them, not so confusing that financial professionals and technology experts struggle to use or understand them.
For those who question the extent to which an organization can fool their way into a security consultancy role, HB Gary should be a great example to look at. Prior to trying to out anonymous, HB Gary was being actively hired by multiple US government agencies and others in the private sector (with glowing testimonials). The published articles and hosted professional security conferences. One should also look at this list of data breaches from the past 2 years. Many of them are large corporations, government entities, and technology companies. These are the ones we know about. Undoubtedly, there are many more that we do not know about. If HB Gary hadn't been "outted" by anonymous, would we have known they were insecure? If the same breach had happened outside of the public spotlight, would it even have been reported? Or would HB Gary have just deleted the Twitter posts, brought their site back up, done a couple patches, and kept on operating as though nothing had happened?
In the case of Quadriga, the facts are clear. Despite past experience with platforms such as MapleChange in Canada and others around the world, no guidance or even the most basic of a framework was put in place by regulators. By not clarifying any sort of legal framework, regulators enabled a situation where a platform could be run by former criminal Mike Dhanini/Omar Patryn, and where funds could be held fully unchecked by one person. At the same time, the lack of regulation deterred legitimate entities from running competing platforms and Quadriga was granted a money services business license for multiple years of operation, which gave the firm the appearance of legitimacy. Regulators did little to protect Canadians despite Quadriga failing to file taxes from 2016 onward. The entire administrative team had resigned and this was public knowledge. Many people had suspicions of what was going on, including Ryan Mueller, who forwarded complaints to the authorities. These were ignored, giving Gerald Cotten the opportunity to escape without justice.
There are multiple issues with the SOC II model including the prohibitive cost (you have to find a third party accounting firm and the prices are not even listed publicly on any sites), the requirement of operating for a year (impossible for new platforms), and lack of any public visibility (SOC II are private reports that aren't shared outside the people in suits).
Securities frameworks are expensive. Sarbanes-Oxley is estimated to cost $5.1 million USD/yr for the average Fortune 500 company in the United States. Since "Fortune 500" represents the top 500 companies, that means well over $2.55 billion USD (~$3.4 billion CAD) is going to people in suits. Isn't the problem of trust and verification the exact problem that the blockchain is supposed to solve?
To use Quadriga as justification for why custodians or SOC II or other advanced schemes are needed for platforms is rather silly, when any framework or visibility at all, or even the most basic of storage policies, would have prevented the whole thing. It's just an embarrassment.
We are now seeing regulators take strong action. CoinSquare in Canada with multi-million dollar fines. BitMex from the US, criminal charges and arrests. OkEx, with full disregard of withdrawals and no communication. Who's next?
We have a unique window today where we can solve these problems, and not permanently destroy innovation with unreasonable expectations, but we need to act quickly. This is a unique historic time that will never come again.
Usually, bull markets attract a lot of new investors - although speculators should be the right word here - and as usual, a lot of them are going to be crushed a way or another. First, before putting a single dollar, euro or whatever in the market, you should read a lot to know exactly what you're looking for. Are you here for the tech and/or the cypherpunk ethos ? Great, there's lot of resources out there (my links are cleaned but as always, do your due diligence) :
The Bitcoin Whitepaper, the one and only : bitcoin.org/bitcoin.pdf Since I'm linking to bitcoin.org, friendly reminder to avoid bitcoin.com, owned by a former supporter now con-artist Roger Ver.
Andreas Antonopoulos website : https://aantonop.com Andreas is one of best guys able to educate on bitcoin and its properties, for free, which helps.
Jameson Lopp website : lopp.net Jameson is a member of Bitcoin Core, cypherpunk, also able to educate a lot. His website is full of free resources and other links. You'll have a lot to read.
Hal Finney : he's unfortunately dead but I would advise to read about Hal Finney, the first to receive bitcoin Satoshi. A great cryptographer, the inventor of the first reusable PoW and one of the first bitcoin supporters. You'll be able to find his messages on this old forum Bitcoin Talk, by the way you'll be able to find the first chats about bitcoin on this forum bitcointalk.org
Monero website : getmonero.org Yep, I know it's gonna be controversial to post an altcoin link but personally, I think that Monero (aka XMR) is the only other coin with a big cypherpunk community, decentralized, and able to help newcomers with a great sense of responsibility, since the ethos here is to save privacy.
What Bitcoin Did : of course, Peter is controversial but I love him and I find his former blog and his podcasts very needed because he doesn't oversell himself. Pete knows that he's not a tech guy (like many of us) and just wants to spread the word, I think he does a good job with this.
Now, you've read and you want to put some skin in the game. Several exchanges are acceptable, a lot of aren't, be careful and assume that none really are (know that I won't post any ref links) :
to me, the best, although it's UI is quite old : Kraken €/$/pound/swiss franc on-off ramp
Coinbase and Coinbase Pro Difficult not to mention Coinbase, although I can't stand Brian Armstrong and the way they are doing their best to support scams currently. You should rather use Coinbase Pro if you have to since the fees are much lower.
Binance Binance came later than the previous ones but has managed to take most of the market. Now, you should remember what I said about being careful.
Huobi The biggest chinese exchange and they work closely with chinese official. Again, careful.
Bittrex Once at the top, now somewhere in the limbs.
A lot of new comers came recently like btse, ftx, feel free to try them while always keeping in mind that once your money is on exchanges, it's not yours anymore.
This was for centralized exchanges aka CEX. Talking about custodial, you'll need wallets to store your (bit)coins. Always try to use non-custodial wallets, which means wallets that give you your private keys. This way, if the software goes down, you can always retreive your money. Now, I won't link to all the existing wallets but will advise you to buy hardware wallets (trezor or ledger but there are others) or to create (on off-gap computers) paper wallets you're able to store safely (against all risks, not only robbery but housefire). You also could use your memory with brain wallets but, my gosh, I wouldn't trust myself. For Bitcoin (or even Litecoin), Electrum software can do a good job (but save your keys). AGAIN, DON'T KEEP YOUR SAVINGS ON AN EXCHANGE Now, about trading : it's been repeated and repeated but don't chase pumps and altcoins. Yep, it's probably the fastest way to make money. It's also the fastest to lose it. I won't lie : I made good money during the 2017-bullrun and I took profits but I also forgot to sell some shitcoins thinking it would keep going up, now I'm still holding these bags (although I don't really care). I know that a lot forgot to take profits. Take profits, always take profits, whatever your strategy is. Don't fall for people trying to sell you their bags, for ICOs trying to sell you a product which isn't released yet and obviously, don't fall for people asking for your private key. Also, know that there's two endgames : accumulating bitcoin or fiat. I'm rather in the first team but whatever your strategy is, take profits. (Yes, I know, some will say accumulating ethereum or something else). It's true that a lot of ethereum holders made a lot of money during the last bullrun (ethereum helped me make money too) but I'm really biased in favor of bitcoin (and monero). So, pick your coin but again, do your due diligence. A lot of people here or there will talk about the best tech, the fact that bitcoin is old and slow. I would need another post to go further on this point but know that a lof of air flight systems are old too but reliable. Trustless and reliable is the point here. This is the post from someone who bought bitcoin seven or six years ago, who lost part of them, who spent part of them (but don't regret this at all), who is still learning and I hope it will help others, although it would need a book to be complete.
How DAO users can truly control their voting rights
https://blockchaintopbuzz.medium.com/how-dao-users-can-truly-control-their-voting-rights-f945c9c6b65e Aelf proposed a solution that gives the control of the voting rights back to users by classifying token permissions. As of today, there are still few complete businesses. In addition to mining and building trading platforms, it is difficult to create a complete business model. Moreover, various trading platforms have gradually grown into enterprises with comprehensive products in the blockchain industry, including wallets, nodes, lending, mining pools, etc. At the same time, cloud services can reduce the cost of building small exchanges, but they can also lead to big trading platforms monopolizing data. For example, some Internet companies provide free cloud services in order to collect more valuable data. Currently, Ethereum, which has the richest DeFi ecosystem, is gradually upgrading to V2.0, and its consensus protocol will also be upgraded to PoS. Governance voting can be regarded as the most important feature in the PoS ecosystem. This year, Yearn.Finance rose to sudden prominence. But due to the governance problem, its community members initiated a hard fork, resulting in YFII. Another DeFi project, YAM, had a unfixable rebase function error. The founding team apologized for the error and announced a ‘Migration Plan’, which will turn the project over to the community. For a while, governance voting became all the rage. However, the increasingly bigger trading platforms have been criticized by users in governance voting. Is there a proper solution to handling the relationship between the trading platform and governance voting?
What will we lose when trading platforms monopolize the blockchain industry?
In June 2018, during the BP node election before the EOS mainnet launch, node voting began to have a crisis of confidence between token holders and the trading platform. it is widely believed that the top 20 holders of trading platform wallets held about 40% of all the EOS in circulation. Since then, many trading platforms have enabled the “User Authorization” interface. EOS holders can authorize the token voting rights to the trading platform, who will vote on behalf of the users. The rule caused a backlash from users, forcing these trading platforms to change the rule immediately so that EOS holders could vote on their preferred BP nodes. After the EOS BP node votes, whether the trading platform has the token voting right has been occasionally discussed, but fewhave noticed it. Two years later, Justin Sun, founder of TRON, made a commercial acquisition of Steemit, a decentralized social networking platform. After the acquisition was announced, the Steemit community launched a soft fork to resist the project being controlled by TRON. However, Justin Sun voted with the support of trading platforms such as Binance, Huobi and Poloniex to prevent a soft fork. After being questioned by users, Binance and Huobi said that they would no longer interfere in the voting of the Steemit community. However, hkdev 404 of the Steem community again reveived votes from Huobi accounts. It is said that nearly 40 million votes were cast during the incident, accounting for about 10% of the total circulation of STEEM tokens. There is no doubt that when the trading platform monopolizes the industry, we will lose our voting right. How do we defend our voting rights The fact that the ownership of the tokens belongs to the holders is indisputable, but what about the voting rights of the tokens deposited on the trading platform? How can we defend our voting rights after trading platforms have monopolized the industry?
Trading Platform Model
Traditional centralized trading platforms will assign to each user a separate deposit address. After depositing, the depositedamount will be added into the cold wallet and hot wallet. When users want to withdraw their tokens, the trading platform will transfer the tokens out of the hot wallet. If there is insufficient balance in the hot wallet, then the tokens will be transferred from the cold wallet to the hot wallet, and then be withdrawn. Under the traditional centralized trading platform model, once users transfer their tokens into a trading platform, it means thetoken ownership (including voting rights) is also transferred to that trading platform. The aelf solution: classify token permissions and claim back voting rights For the issue of “voting rights” between token holders and centralized trading platforms, aelf, a decentralized cloud computing blockchain network, has proposed a solution: to establish an aelf Centre Asset Management Contract on the chain. The contract can limit the funds entering the exchange and define different permissions to control the assets. The main feature of the aelf Centre Asset Management Contract is to create the “Main Virtual Address of the Trading Platform”. Each exchange has a main virtual address, which can only be used for transfer operation, but not for voting, trading and other operations. As a result, the exchange cannot misappropriate users’ assets for voting. At the same time, the assets of the primary virtual address are publicly available on the chain, which makes it more difficult for the exchange to misappropriate assets. At the same time, the aelf Centre Asset Management Contract also has the function of “address definition”. The exchange can open different permissions to different addresses, such as opening different permissions according to the amount, transactions exceeding a certain amount can only be given the greenlight by using multiple signatures, and the assets can be frozen through the contract when the assets of the trading platform are stolen, etc. For the users of the trading platform, the access of the trading platform to the aelf Center Asset Management Contract function will not undermine user experience. The virtual system address of the aelf Center Asset Management Contract will assign a virtual address to each user, which offers the same user experience as the traditional mode. For the trading platform, each deposit address constructed by the virtual address system is generated by the algorithm and does not need to be carried out on the blockchain. This means that the trading platform does not need to manage a large number of private keys, and there is no risk that the private keys will be lost. On the most important “voting rights” issue, the aelf Center Asset Management Contract will assign to each user a separate virtual address for voting: Voting address = Hash (Exchange Main Address + Token + “VOTE”) Voting process: the tokens are transferred from the main virtual address of the exchange to the special “voting address” for voting, and are then voted. After voting, the tokens are withdrawn from the voting address back to the main virtual address. We can see that the aelf Centre Asset Management Contract proposed by aelf can improve the efficiency of the trading platform without affecting user experience. In addition, it solves the problem that users would lose their voting rights. According to the data on Crypto Mode, the market value of PoS tokens has exceeded $33 billion without counting Ethereum. In the field of crypto, it is the biggest ecosystem next to Bitcoin. The most important function of PoS is vote staking. faced with bigtrading platforms, if the status quo continues, retail investors will gradually lose their “voting rights” that belong to them. Comparison of Market Value of PoS tokens (Source: Crypto Mode) The emergence of DAO offers an alternative to trading platforms who misappropriate users’ tokens, but it still can not change this situation. Of course, DAO will not die out. Small communities will still use DAO for community governance. The idea behind the design of aelf is to start from the underlying trading platform and solve this issue at the source. Whether the solution can work still takes time. However, as a member of the crypto industry, we should understand the importance of “voting rights”, and cannot allow the exchange to seize our rights at will. Recently, aelf has also announced its DeFi plan, which includes a new blockchain 3.0 project with a large number of new technical features, such as cross chain function, virtual address and cloud services. Aelf also proposed a set of interoperability solutions with ERC-20 tokens. It can directly access the ETH ecosystem, allow ETH-based applications and wallets to directly access it, and maintain the interoperability with ETH. And aelf will provide a high-performance smart contract operation platform and cloud services that can support cross chain interaction. Users on major cloud servers can easily run aelf’s services and adjust the scale of cloud according to their own business needs. The implementation of a slew of tools, cloud services and interoperability solutions developed by aelf means that centralized transactions can be directly connected to the aelf network, realizing one-click adaptation to the DeFi ecosystem. With aelf, CeFi and DeFi are able to learn from and complement each other.
How To End The Cryptocurrency Exchange "Wild West" Without Crippling Innovation
In case you haven't noticed the consultation paper, staff notice, and report on Quadriga, regulators are now clamping down on Canadian cryptocurrency exchanges. The OSC and other regulatory bodies are still interested in industry feedback. They have not put forward any official regulation yet. Below are some ideas/insights and a proposed framework.
Typical securities frameworks will cost Canadians millions of dollars (ie Sarbanes-Oxley estimated at $5m USD/yr per firm). Implementation costs of this proposal are significantly cheaper.
Canadians can maintain a diverse set of exchanges, multiple viable business models are still fully supported, and innovation is encouraged while keeping Canadians safe.
Many of you have limited time to read the full proposal, so here are the highlights:
Effective standards to prevent both internal and external theft. Exchange operators are trained and certified, and have a legal responsibility to users.
Regular Transparent Audits
Provides visibility to Canadians that their funds are fully backed on the exchange, while protecting privacy and sensitive platform information.
Establishment of basic insurance standards/strategy, to expand over time. Removing risk to exchange users of any hot wallet theft.
Background and Justifications
Cold Storage Custody/Management After reviewing close to 100 cases, all thefts tend to break down into more or less the same set of problems: • Funds stored online or in a smart contract, • Access controlled by one person or one system, • 51% attacks (rare), • Funds sent to the wrong address (also rare), or • Some combination of the above. For the first two cases, practical solutions exist and are widely implemented on exchanges already. Offline multi-signature solutions are already industry standard. No cases studied found an external theft or exit scam involving an offline multi-signature wallet implementation. Security can be further improved through minimum numbers of signatories, background checks, providing autonomy and legal protections to each signatory, establishing best practices, and a training/certification program. The last two transaction risks occur more rarely, and have never resulted in a loss affecting the actual users of the exchange. In all cases to date where operators made the mistake, they've been fully covered by the exchange platforms. • 51% attacks generally only occur on blockchains with less security. The most prominent cases have been Bitcoin Gold and Ethereum Classic. The simple solution is to enforce deposit limits and block delays such that a 51% attack is not cost-effective. • The risk of transactions to incorrect addresses can be eliminated by a simple test transaction policy on large transactions. By sending a small amount of funds prior to any large withdrawals/transfers as a standard practice, the accuracy of the wallet address can be validated. The proposal covers all loss cases and goes beyond, while avoiding significant additional costs, risks, and limitations which may be associated with other frameworks like SOC II. On The Subject of Third Party Custodians Many Canadian platforms are currently experimenting with third party custody. From the standpoint of the exchange operator, they can liberate themselves from some responsibility of custody, passing that off to someone else. For regulators, it puts crypto in similar categorization to oil, gold, and other commodities, with some common standards. Platform users would likely feel greater confidence if the custodian was a brand they recognized. If the custodian was knowledgeable and had a decent team that employed multi-sig, they could keep assets safe from internal theft. With the right protections in place, this could be a great solution for many exchanges, particularly those that lack the relevant experience or human resources for their own custody systems. However, this system is vulnerable to anyone able to impersonate the exchange operators. You may have a situation where different employees who don't know each other that well are interacting between different companies (both the custodian and all their customers which presumably isn't just one exchange). A case study of what can go wrong in this type of environment might be Bitpay, where the CEO was tricked out of 5000 bitcoins over 3 separate payments by a series of emails sent legitimately from a breached computer of another company CEO. It's also still vulnerable to the platform being compromised, as in the really large $70M Bitfinex hack, where the third party Bitgo held one key in a multi-sig wallet. The hacker simply authorized the withdrawal using the same credentials as Bitfinex (requesting Bitgo to sign multiple withdrawal transactions). This succeeded even with the use of multi-sig and two heavily security-focused companies, due to the lack of human oversight (basically, hot wallet). Of course, you can learn from these cases and improve the security, but so can hackers improve their deception and at the end of the day, both of these would have been stopped by the much simpler solution of a qualified team who knew each other and employed multi-sig with properly protected keys. It's pretty hard to beat a human being who knows the business and the typical customer behaviour (or even knows their customers personally) at spotting fraud, and the proposed multi-sig means any hacker has to get through the scrutiny of 3 (or more) separate people, all of whom would have proper training including historical case studies. There are strong arguments both for and against using use of third party custodians. The proposal sets mandatory minimum custody standards would apply regardless if the cold wallet signatories are exchange operators, independent custodians, or a mix of both. On The Subject Of Insurance ShakePay has taken the first steps into this new realm (congratulations). There is no question that crypto users could be better protected by the right insurance policies, and it certainly feels better to transact with insured platforms. The steps required to obtain insurance generally place attention in valuable security areas, and in this case included a review from CipherTrace. One of the key solutions in traditional finance comes from insurance from entities such as the CDIC. However, historically, there wasn't found any actual insurance payout to any cryptocurrency exchange, and there are notable cases where insurance has not paid. With Bitpay, for example, the insurance agent refused because the issue happened to the third party CEO's computer instead of anything to do with Bitpay itself. With the Youbit exchange in South Korea, their insurance claim was denied, and the exchange ultimately ended up instead going bankrupt with all user's funds lost. To quote Matt Johnson in the original Lloyd's article: “You can create an insurance policy that protects no one – you know there are so many caveats to the policy that it’s not super protective.” ShakePay's insurance was only reported to cover their cold storage, and “physical theft of the media where the private keys are held”. Physical theft has never, in the history of cryptocurrency exchange cases reviewed, been reported as the cause of loss. From the limited information of the article, ShakePay made it clear their funds are in the hands of a single US custodian, and at least part of their security strategy is to "decline to confirm the custodian’s name on the record". While this prevents scrutiny of the custodian, it's pretty silly to speculate that a reasonably competent hacking group couldn't determine who the custodian is. A far more common infiltration strategy historically would be social engineering, which has succeeded repeatedly. A hacker could trick their way into ShakePay's systems and request a fraudulent withdrawal, impersonate ShakePay and request the custodian to move funds, or socially engineer their way into the custodian to initiate the withdrawal of multiple accounts (a payout much larger than ShakePay) exploiting the standard procedures (for example, fraudulently initiating or override the wallet addresses of a real transfer). In each case, nothing was physically stolen and the loss is therefore not covered by insurance. In order for any insurance to be effective, clear policies have to be established about what needs to be covered. Anything short of that gives Canadians false confidence that they are protected when they aren't in any meaningful way. At this time, the third party insurance market does not appear to provide adequate options or coverage, and effort is necessary to standardize custody standards, which is a likely first step in ultimately setting up an insurance framework. A better solution compared to third party insurance providers might be for Canadian exchange operators to create their own collective insurance fund, or a specific federal organization similar to the CDIC. Such an organization would have a greater interest or obligation in paying out actual cases, and that would be it's purpose rather than maximizing it's own profit. This would be similar to the SAFU which Binance has launched, except it would cover multiple exchanges. There is little question whether the SAFU would pay out given a breach of Binance, and a similar argument could be made for a insurance fund managed by a collective of exchange operators or a government organization. While a third party insurance provider has the strong market incentive to provide the absolute minimum coverage and no market incentive to payout, an entity managed by exchange operators would have incentive to protect the reputation of exchange operators/the industry, and the government should have the interest of protecting Canadians. On The Subject of Fractional Reserve There is a long history of fractional reserve failures, from the first banks in ancient times, through the great depression (where hundreds of fractional reserve banks failed), right through to the 2008 banking collapse referenced in the first bitcoin block. The fractional reserve system allows banks to multiply the money supply far beyond the actual cash (or other assets) in existence, backed only by a system of debt obligations of others. Safely supporting a fractional reserve system is a topic of far greater complexity than can be addressed by a simple policy, and when it comes to cryptocurrency, there is presently no entity reasonably able to bail anyone out in the event of failure. Therefore, this framework is addressed around entities that aim to maintain 100% backing of funds. There may be some firms that desire but have failed to maintain 100% backing. In this case, there are multiple solutions, including outside investment, merging with other exchanges, or enforcing a gradual restoration plan. All of these solutions are typically far better than shutting down the exchange, and there are multiple cases where they've been used successfully in the past. Proof of Reserves/Transparency/Accountability Canadians need to have visibility into the backing on an ongoing basis. The best solution for crypto-assets is a Proof of Reserve. Such ideas go back all the way to 2013, before even Mt. Gox. However, no Canadian exchange has yet implemented such a system, and only a few international exchanges (CoinFloor in the UK being an example) have. Many firms like Kraken, BitBuy, and now ShakePay use the Proof of Reserve term to refer to lesser proofs which do not actually cryptographically prove the full backing of all user assets on the blockchain. In order for a Proof of Reserve to be effective, it must actually be a complete proof, and it needs to be understood by the public that is expected to use it. Many firms have expressed reservations about the level of transparency required in a complete Proof of Reserve (for example Kraken here). While a complete Proof of Reserves should be encouraged, and there are some solutions in the works (ie TxQuick), this is unlikely to be suitable universally for all exchange operators and users. Given the limitations, and that firms also manage fiat assets, a more traditional audit process makes more sense. Some Canadian exchanges (CoinSquare, CoinBerry) have already subjected themselves to annual audits. However, these results are not presently shared publicly, and there is no guarantee over the process including all user assets or the integrity and independence of the auditor. The auditor has been typically not known, and in some cases, the identity of the auditor is protected by a NDA. Only in one case (BitBuy) was an actual report generated and publicly shared. There has been no attempt made to validate that user accounts provided during these audits have been complete or accurate. A fraudulent fractional exchange, or one which had suffered a breach they were unwilling to publicly accept (see CoinBene), could easily maintain a second set of books for auditors or simply exclude key accounts to pass an individual audit. The proposed solution would see a reporting standard which includes at a minimum - percentage of backing for each asset relative to account balances and the nature of how those assets are stored, with ownership proven by the auditor. The auditor would also publicly provide a "hash list", which they independently generate from the accounts provided by the exchange. Every exchange user can then check their information against this public "hash list". A hash is a one-way form of encryption, which fully protects the private information, yet allows anyone who knows that information already to validate that it was included. Less experienced users can take advantage of public tools to calculate the hash from their information (provided by the exchange), and thus have certainty that the auditor received their full balance information. Easy instructions can be provided. Auditors should be impartial, their identities and process public, and they should be rotated so that the same auditor is never used twice in a row. Balancing the cost of auditing against the needs for regular updates, a 6 month cycle likely makes the most sense. Hot Wallet Management The best solution for hot wallets is not to use them. CoinBerry reportedly uses multi-sig on all withdrawals, and Bitmex is an international example known for their structure devoid of hot wallets. However, many platforms and customers desire fast withdrawal processes, and human validation has a cost of time and delay in this process. A model of self-insurance or separate funds for hot wallets may be used in these cases. Under this model, a platform still has 100% of their client balance in cold storage and holds additional funds in hot wallets for quick withdrawal. Thus, the risk of those hot wallets is 100% on exchange operators and not affecting the exchange users. Since most platforms typically only have 1%-5% in hot wallets at any given time, it shouldn't be unreasonable to build/maintain these additional reserves over time using exchange fees or additional investment. Larger withdrawals would still be handled at regular intervals from the cold storage. Hot wallet risks have historically posed a large risk and there is no established standard to guarantee secure hot wallets. When the government of South Korea dispatched security inspections to multiple exchanges, the results were still that 3 of them got hacked after the inspections. If standards develop such that an organization in the market is willing to insure the hot wallets, this could provide an acceptable alternative. Another option may be for multiple exchange operators to pool funds aside for a hot wallet insurance fund. Comprehensive coverage standards must be established and maintained for all hot wallet balances to make sure Canadians are adequately protected.
Current Draft Proposal
(1) Proper multi-signature cold wallet storage. (a) Each private key is the personal and legal responsibility of one person - the “signatory”. Signatories have special rights and responsibilities to protect user assets. Signatories are trained and certified through a course covering (1) past hacking and fraud cases, (2) proper and secure key generation, and (3) proper safekeeping of private keys. All private keys must be generated and stored 100% offline by the signatory. If even one private keys is ever breached or suspected to be breached, the wallet must be regenerated and all funds relocated to a new wallet. (b) All signatories must be separate background-checked individuals free of past criminal conviction. Canadians should have a right to know who holds their funds. All signing of transactions must take place with all signatories on Canadian soil or on the soil of a country with a solid legal system which agrees to uphold and support these rules (from an established white-list of countries which expands over time). (c) 3-5 independent signatures are required for any withdrawal. There must be 1-3 spare signatories, and a maximum of 7 total signatories. The following are all valid combinations: 3of4, 3of5, 3of6, 4of5, 4of6, 4of7, 5of6, or 5of7. (d) A security audit should be conducted to validate the cold wallet is set up correctly and provide any additional pertinent information. The primary purpose is to ensure that all signatories are acting independently and using best practices for private key storage. A report summarizing all steps taken and who did the audit will be made public. Canadians must be able to validate the right measures are in place to protect their funds. (e) There is a simple approval process if signatories wish to visit any country outside Canada, with a potential whitelist of exempt countries. At most 2 signatories can be outside of aligned jurisdiction at any given time. All exchanges would be required to keep a compliant cold wallet for Canadian funds and have a Canadian office if they wish to serve Canadian customers. (2) Regular and transparent solvency audits. (a) An audit must be conducted at founding, after 3 months of operation, and at least once every 6 months to compare customer balances against all stored cryptocurrency and fiat balances. The auditor must be known, independent, and never the same twice in a row. (b) An audit report will be published featuring the steps conducted in a readable format. This should be made available to all Canadians on the exchange website and on a government website. The report must include what percentage of each customer asset is backed on the exchange, and how those funds are stored. (c) The auditor will independently produce a hash of each customer's identifying information and balance as they perform the audit. This will be made publicly available on the exchange and government website, along with simplified instructions that each customer can use to verify that their balance was included in the audit process. (d) The audit needs to include a proof of ownership for any cryptocurrency wallets included. A satoshi test (spending a small amount) or partially signed transaction both qualify. (e) Any platform without 100% reserves should be assessed on a regular basis by a government or industry watchdog. This entity should work to prevent any further drop, support any private investor to come in, or facilitate a merger so that 100% backing can be obtained as soon as possible. (3) Protections for hot wallets and transactions. (a) A standardized list of approved coins and procedures will be established to constitute valid cold storage wallets. Where a multi-sig process is not natively available, efforts will be undertaken to establish a suitable and stable smart contract standard. This list will be expanded and improved over time. Coins and procedures not on the list are considered hot wallets. (b) Hot wallets can be backed by additional funds in cold storage or an acceptable third-party insurance provider with a comprehensive coverage policy. (c) Exchanges are required to cover the full balance of all user funds as denominated in the same currency, or double the balance as denominated in bitcoin or CAD using an established trading rate. If the balance is ever insufficient due to market movements, the firm must rectify this within 24 hours by moving assets to cold storage or increasing insurance coverage. (d) Any large transactions (above a set threshold) from cold storage to any new wallet addresses (not previously transacted with) must be tested with a smaller transaction first. Deposits of cryptocurrency must be limited to prevent economic 51% attacks. Any issues are to be covered by the exchange. (e) Exchange platforms must provide suitable authentication for users, including making available approved forms of two-factor authentication. SMS-based authentication is not to be supported. Withdrawals must be blocked for 48 hours in the event of any account password change. Disputes on the negligence of exchanges should be governed by case law.
Continued review of existing OSC feedback is still underway. More feedback and opinions on the framework and ideas as presented here are extremely valuable. The above is a draft and not finalized. The process of further developing and bringing a suitable framework to protect Canadians will require the support of exchange operators, legal experts, and many others in the community. The costs of not doing such are tremendous. A large and convoluted framework, one based on flawed ideas or implementation, or one which fails to properly safeguard Canadians is not just extremely expensive and risky for all Canadians, severely limiting to the credibility and reputation of the industry, but an existential risk to many exchanges. The responsibility falls to all of us to provide our insight and make our opinions heard on this critical matter. Please take the time to give your thoughts.
The events of a SIM swap attack (and defense tips)
Posted this on Coinbase and someone recommend it also be posted here. The information below on an attempted SIM swap attack was pieced together through a combination of login and security logs, recovering emails initiated by the attacker that were deleted and then deleted again from the trash folder, and learning from AT&T’s fraud representatives. The majority if this is factual, and we do our best to note where we are speculating or providing a circumstantial suspicion. TLDRs at the bottom. The full story: We were going about our business and received a text from AT&T that says “…Calls & texts will go to your new phone/SIM card. Call 866-563-4705 if you did not request.” We did not request this, and were suspicious that the text itself could be a phishing scam since we searched the phone number and it wasn’t overtly associated with AT&T. Thus, we tried calling AT&T’s main line at 611 but all we hear is beep beep beep. The phone number is already gone. We use another phone to call AT&T and at the same time start working on our already compromised email. While we didn’t see everything real time, this is what the recovered emails show. In less than 2 minutes after receiving the text from AT&T, there is already an email indicating that the stolen phone number was used to sign into our email account associated with Coinbase. 2 minutes after that, there is an email from Coinbase saying: "We have received your request for password reset from an unverified device. As a security precaution, an e-mail with a reset link will be sent to you in 24 hours. Alternatively, if you would like your password reset to be processed immediately, please submit a request using a verified device. This 24 hour review period is designed to protect your Coinbase account." This is where Coinbase got it right to have a 24 hour review period (actually a recovery period) before allowing the password to be reset. However, the attackers knew this and planned to steal the second email from Coinbase by setting email rules to forward all emails to a burner address and also have any emails containing “coinbase” re-routed so they don’t appear in the Inbox. 5 minutes later, they request a password reset from Gemini and the password was reset to the attacker’s password within a minute after that. The next minute they target and reset DropBox’s password followed immediately with Binance. Less than 2 minutes later, an email from Binance indicates that the password has been reset and another email arrives a minute later indicating a new device has been authorized. It’s at this point that we begin locking the attacker out by (1) removing the phone number as 2FA (2) changing the email password, (3) and three forcing a logout of all sessions from the email. There was a bit of back and forth where they still had an active login and re-added the stolen phone number as 2FA. They added only one more password reset to a gaming account that was not deleted. I can only suspect that was a decoy to make it look like the attack was directed at gaming rather than finances. The Gemini and Binance accounts were empty and effectively abandoned, with no balances and inactive bank accounts (if any), and no transactions in 1-3 years. DropBox had no meaningful files (they probably look for private keys and authenticator backups) and the phone number they stole from us was suspended, so as far as the attacker is concerned, there is no meat on this bone to attack again… unless they had inside information. This is where I suspect someone internal at Coinbase receiving wire deposits has been compromised in tipping off ripe accounts – accounts with new and somewhat large balances. We had completed a full withdrawal of funds from Coinbase earlier in the year, and had a balance of less than $20 heading into May. Deposits to Coinbase staggered in to get above six figures through mid-May then stopped. The attack occurred 7 days after the last large wire deposit was made to Coinbase. From the perspective of an attacker that had no inside information, we were a dead end with abandoned Gemini and Binance accounts with zero balances and stale transactions, no DropBox information, and the suspended phone number access. Our Coinbase deposits were known to no one except us, Coinbase, and our bank. We were also able to stop the hacker’s email forwarding before Coinbase’s 24 hour period to send the password reset, so this one didn’t work out for the attackers and it would make sense for them to move on to the next rather than put efforts into a second attack only for Coinbase - for what would appear to be a zero-balance Coinbase account based on the other stale accounts. Then…23 hours and 42 minutes after the first attack, another message from AT&T “…Calls & texts will go to your new phone/SIM card. Call 866-563-4705 if you did not request.” Here we go again. We had been confident in AT&T’s assurances that our account had been locked and would not be SIM swapped again, so we unwisely added the phone number back to our email account as a backup (it’s now removed permanently and we use burner emails for account recovery like we should have all along). Upon seeing that our phone number had been stolen again I knew they were after the Coinbase reset email that was delayed by 24 hours from Coinbase as part of their security. We did 4 things within 2 minutes of that text: (1) removed the phone number again from the email account – this time for good, (2) market sell all Bitcoin on Coinbase, (3) withdraw from Coinbase, (4) have AT&T suspend service on the phone line. In speaking with AT&T, they were floored that our SIM would be transferred again in light of all the notes about fraud on the account and the PIN being changed to random digits that had never been used by us before. Based on the response of disbelief from AT&T on the second port, I suspect that this attack also involved a compromised AT&T employee that worked with the attacker to provide timely access to the Coinbase password reset email. Apparently, this has been going on for years: https://www.flashpoint-intel.com/blog/sim-swap-fraud-account-takeove with phone carrier employees swapping SIMs for $80s a swap. Remember that most of this was hidden in real time, and was only known because we were able to recover emails deleted from Trash by the attacker. Since we require any withdrawals to use Google Authenticator on Coinbase, our funds may have been secure nonetheless. However, under the circumstances with attackers that were apparently working with insiders to take our phone number twice in attempts to steal Bitcoin, and it being unknown if they had additional tools related to our Google Authenticator, we decided it was safer on the sidelines. The coins were held on the exchange for a quick exit depending on whether Bitcoin was going to break up or down from $10,000. A hardware wallet is always safest, but we were looking to time the market and not have transaction delays. For some some security recommendations: AT&T: If you are going to send a text saying that calls and texts are moving to a new number, provide a 10 minute window for the phone number to reply with a “NO” or “STOP” to prevent the move. This can escalate the SIM dispute to more trusted employees to determine who actually owns the line. Don’t let entry level employees swap SIMs. Coinbase: Do not default to phone numbers as 2FA. Also, if someone logs in successfully with the password before the 24 hours are up, the password is known and there is no need to send the password reset email again for attacker to have forwarded to them. At least have an option to stop the password reset email from being sent. We did not tag our account at Coinbase with fraud because of the stories of frozen funds once an account is tagged. I’m not sure what the solution is there, but that is another problem. Being a trader, it would be nice to think of Coinbase as any other type of security brokerage where your assets are yours (someone can’t steal your phone number and transfer your stocks to their account). We fell into that mindset of security, yet this experience has reminded us of the uniqueness of cryptocurrency and the lack of custodial assurance and insurance from exchanges because of the possession-is-everything properties of cryptocurrency. As many have said before, 2FA with a phone number quickly becomes 1-factor authentication as soon as that phone number is associated with password recovery on your email or other accounts. Our overall recommendation is to avoid having a phone number associated with any recovery options across all your accounts. TLDR on the process: Scammers will steal your phone number (in our case twice in 24 hours) and use your phone number to access your email and accounts. They will use your email to reset passwords at financial accounts and file hosting such as DropBox. They will then use that combination to transfer any assets they can access from your accounts to theirs. They will do their best to hide this from you by (1) not resetting your email password so as to raise suspicion, (2) immediately delete any password reset emails you may receive from financial accounts to hide them from you, (3) attempt to forward all emails sent to your address to a burner email, and (4) set email rules to forward emails containing “coinbase” to an email folder other than your Inbox so that you don’t see the transactions and password reset emails that arrive to your inbox. TLDR on defense tips: If your phone stops working or you receive a text of your number being ported do the following as soon as possible: (1) log into your email account(s) associated with your financial accounts and remove your phone number as 2FA immediately (2) change your email password, (3) force a logout of all sessions from your email (at this point you have locked them out), then (4) check your mail forwarding settings for forwards to burner addresses, (5) check your mail rules for rerouting of emails from accounts such as Coinbase, and (6) call your carrier to have them suspend service on your lost phone number and ask them to reinstate your SIM or get a new SIM. This will require a second phone because your personal phone number has been stolen. We hope this helps some others be safe out there in protecting their coins. The more we know, the more we can protect ourselves. Wishing you all the best!
The events of a SIM swap attack directed at Coinbase (and defense tips)
The information below on an attempted SIM swap attack was pieced together through a combination of login and security logs, recovering emails initiated by the attacker that were deleted and then deleted again from the trash folder, and learning from AT&T’s fraud representatives. The majority if this is factual, and we do our best to note where we are speculating or providing a circumstantial suspicion. TLDRs at the bottom. The full story: We were going about our business and received a text from AT&T that says “…Calls & texts will go to your new phone/SIM card. Call 866-563-4705 if you did not request.” We did not request this, and were suspicious that the text itself could be a phishing scam since we searched the phone number and it wasn’t overtly associated with AT&T. Thus, we tried calling AT&T’s main line at 611 but all we hear is beep beep beep. The phone number is already gone. We use another phone to call AT&T and at the same time start working on our already compromised email. While we didn’t see everything real time, this is what the recovered emails show. In less than 2 minutes after receiving the text from AT&T, there is already an email indicating that the stolen phone number was used to sign into our email account associated with Coinbase. 2 minutes after that, there is an email from Coinbase saying: "We have received your request for password reset from an unverified device. As a security precaution, an e-mail with a reset link will be sent to you in 24 hours. Alternatively, if you would like your password reset to be processed immediately, please submit a request using a verified device. This 24 hour review period is designed to protect your Coinbase account." This is where Coinbase got it right to have a 24 hour review period (actually a recovery period) before allowing the password to be reset. However, the attackers knew this and planned to steal the second email from Coinbase by setting email rules to forward all emails to a burner address and also have any emails containing “coinbase” re-routed so they don’t appear in the Inbox. 5 minutes later, they request a password reset from Gemini and the password was reset to the attacker’s password within a minute after that. The next minute they target and reset DropBox’s password followed immediately with Binance. Less than 2 minutes later, an email from Binance indicates that the password has been reset and another email arrives a minute later indicating a new device has been authorized. It’s at this point that we begin locking the attacker out by (1) removing the phone number as 2FA (2) changing the email password, (3) and three forcing a logout of all sessions from the email. There was a bit of back and forth where they still had an active login and re-added the stolen phone number as 2FA. They added only one more password reset to a gaming account that was not deleted. I can only suspect that was a decoy to make it look like the attack was directed at gaming rather than finances. The Gemini and Binance accounts were empty and effectively abandoned, with no balances and inactive bank accounts (if any), and no transactions in 1-3 years. DropBox had no meaningful files (they probably look for private keys and authenticator backups) and the phone number they stole from us was suspended, so as far as the attacker is concerned, there is no meat on this bone to attack again… unless they had inside information. This is where I suspect someone internal at Coinbase receiving wire deposits has been compromised in tipping off ripe accounts – accounts with new and somewhat large balances. We had completed a full withdrawal of funds from Coinbase earlier in the year, and had a balance of less than $20 heading into May. Deposits to Coinbase staggered in to get above six figures through mid-May then stopped. The attack occurred 7 days after the last large wire deposit was made to Coinbase. From the perspective of an attacker that had no inside information, we were a dead end with abandoned Gemini and Binance accounts with zero balances and stale transactions, no DropBox information, and the suspended phone number access. Our Coinbase deposits were known to no one except us, Coinbase, and our bank. We were also able to stop the hacker’s email forwarding before Coinbase’s 24 hour period to send the password reset, so this one didn’t work out for the attackers and it would make sense for them to move on to the next rather than put efforts into a second attack only for Coinbase - for what would appear to be a zero-balance Coinbase account based on the other stale accounts. Then…23 hours and 42 minutes after the first attack, another message from AT&T “…Calls & texts will go to your new phone/SIM card. Call 866-563-4705 if you did not request.” Here we go again. We had been confident in AT&T’s assurances that our account had been locked and would not be SIM swapped again, so we unwisely added the phone number back to our email account as a backup (it’s now removed permanently and we use burner emails for account recovery like we should have all along). Upon seeing that our phone number had been stolen again I knew they were after the Coinbase reset email that was delayed by 24 hours from Coinbase as part of their security. We did 4 things within 2 minutes of that text: (1) removed the phone number again from the email account – this time for good, (2) market sell all Bitcoin on Coinbase, (3) withdraw from Coinbase, (4) have AT&T suspend service on the phone line. In speaking with AT&T, they were floored that our SIM would be transferred again in light of all the notes about fraud on the account and the PIN being changed to random digits that had never been used by us before. Based on the response of disbelief from AT&T on the second port, I suspect that this attack also involved a compromised AT&T employee that worked with the attacker to provide timely access to the Coinbase password reset email. Apparently, this has been going on for years: https://www.flashpoint-intel.com/blog/sim-swap-fraud-account-takeove with phone carrier employees swapping SIMs for $80s a swap. Remember that most of this was hidden in real time, and was only known because we were able to recover emails deleted from Trash by the attacker. Since we require any withdrawals to use Google Authenticator on Coinbase, our funds may have been secure nonetheless. However, under the circumstances with attackers that were apparently working with insiders to take our phone number twice in attempts to steal Bitcoin, and it being unknown if they had additional tools related to our Google Authenticator, we decided it was safer on the sidelines. The coins were held on the exchange for a quick exit depending on whether Bitcoin was going to break up or down from $10,000. A hardware wallet is always safest, but we were looking to time the market and not have transaction delays. For some some security recommendations: AT&T: If you are going to send a text saying that calls and texts are moving to a new number, provide a 10 minute window for the phone number to reply with a “NO” or “STOP” to prevent the move. This can escalate the SIM dispute to more trusted employees to determine who actually owns the line. Don’t let entry level employees swap SIMs. Coinbase: Do not default to phone numbers as 2FA. Also, if someone logs in successfully with the password before the 24 hours are up, the password is known and there is no need to send the password reset email again for attacker to have forwarded to them. At least have an option to stop the password reset email from being sent. We did not tag our account at Coinbase with fraud because of the stories of frozen funds once an account is tagged. I’m not sure what the solution is there, but that is another problem. Being a trader, it would be nice to think of Coinbase as any other type of security brokerage where your assets are yours (someone can’t steal your phone number and transfer your stocks to their account). We fell into that mindset of security, yet this experience has reminded us of the uniqueness of cryptocurrency and the lack of custodial assurance and insurance from exchanges because of the possession-is-everything properties of cryptocurrency. As many have said before, 2FA with a phone number quickly becomes 1-factor authentication as soon as that phone number is associated with password recovery on your email or other accounts. Our overall recommendation is to avoid having a phone number associated with any recovery options across all your accounts. TLDR on the process: Scammers will steal your phone number (in our case twice in 24 hours) and use your phone number to access your email and accounts. They will use your email to reset passwords at financial accounts and file hosting such as DropBox. They will then use that combination to transfer any assets they can access from your accounts to theirs. They will do their best to hide this from you by (1) not resetting your email password so as to raise suspicion, (2) immediately delete any password reset emails you may receive from financial accounts to hide them from you, (3) attempt to forward all emails sent to your address to a burner email, and (4) set email rules to forward emails containing “coinbase” to an email folder other than your Inbox so that you don’t see the transactions and password reset emails that arrive to your inbox. TLDR on defense tips: If your phone stops working or you receive a text of your number being ported do the following as soon as possible: (1) log into your email account(s) associated with your financial accounts and remove your phone number as 2FA immediately (2) change your email password, (3) force a logout of all sessions from your email (at this point you have locked them out), then (4) check your mail forwarding settings for forwards to burner addresses, (5) check your mail rules for rerouting of emails from accounts such as Coinbase, and (6) call your carrier to have them suspend service on your lost phone number and ask them to reinstate your SIM or get a new SIM. This will require a second phone because your personal phone number has been stolen. We hope this helps some others be safe out there in protecting their coins. The more we know, the more we can protect ourselves. Wishing you all the best!
AMA Recap of CEO and Co-founder of Chromia, Henrik Hjelte in the @binancenigeria Telegram group on 03/05/2020.
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