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.
- Over $200m has been stolen impersonating users of cryptocurrency platforms by one group alone. Here's a list of 10 social engineering attacks against corporate companies. Here's an even larger case. While verification methods are improving, so are methods of identity theft and social engineering. We now have sim swapping and deep fake videos to contend with. Hackers have massive database sets of personal information they can utilize. As the sums at stake increase, so to will the level of effort criminals are willing to undertake. Obscurity for an insecure system will only postpone an attack until the "jackpot" is large enough.
- 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.
I want to thank everyone who replied to our survey! Your feedback is extremely valuable!
Here are the results and how they're helping shape our direction.
What goals would you like to see us accomplish? What's most important to you in how this Quadriga situation ends?
This was an open-ended question and the answers varied widely (and there was definitely a lot of responses which mentioned multiple goals). Here's a summary:
- 65% mentioned recovering losses for affected users.
- 45% described a desire to get better standards on Canadian exchanges.
- 30% included justice for victims.
- 25% desired education on crypto-asset protection.
- 20% had the creation of the new exchange.
The justice theme has been entirely overlooked by what we're doing. Discussing the idea on the Quadriga Uncovered Telegram group, it was determined that there was definite interest in a potential letter-writing initiative. One possibility would be sending letters to the RCMP to request the exhumation.
Is there any part of our initiative which confuses you?
Almost universally, there was no mention of any confusion.
The feedback we did receive:
- "The website landing page could provide an executive summary of the key aspects of the initiative".
- The front page was last updated March 30th. We are constantly experimenting and improving the front of the website and our presentation of ideas and welcome any insight.
- "I was worried with the proposal to have a token for affected users. The intention may be ok, but tokens and ICOs have a bad reputation for being scams. I confess that I didn't read the website of the Initiative, but from communications, I didn't see the association between the Initiative and the official committee."
- We should make clear we are fully separate from the bankruptcy process. There is no tie to the official committee, although we have gotten their feedback throughout. This is an opportunity for the business community to provide additional help for victims.
- We are contemplating the need for having blockchain-backing, however it does provide the ability to have greater transparency in the distribution/supply, more control in the form of a multi-sig smart contract, and easier liquidity options.
- What we are doing is fundamentally different from any ICO. Tokens are distributed 100% free against verified losses. Redemption happens over time for utility (products/services) or goodwill (best-effort redemption) and it's always a fixed value of $1.
- "Generally i understand. Confused about progress and value offer to crypto enthusiasts."
- The initial (very first) value proposition for the tokens will be the ability to offset trading fees on the partner exchange, where we expect that traders may adopt having a small stash to cover their trading expenses as they trade. From there, we have other businesses interested in accepting partial payment in tokens. Basically, tokens are spent in place of dollars to get a discount at participating businesses which wish to support affected users.
- In terms of progress, we are still waiting for three things:
- Partner exchange full launch.
- First bankruptcy payout to complete.
- Reaching 1,000 signups (as necessary for our deal).
Please feel free to reach out on Telegram and Reddit if there are any further questions!
Is it more important to you that we focus on (a) helping victims of Quadriga recover, (b) educating more people about Quadriga and other exchange fraud, or (c) preventing future exchange fraud events like Quadriga?
Of the first or only choice picked, 70% chose (a) helping victims of Quadriga recover, while 30% chose (c) preventing future exchange fraud events like Quadriga.
(a) was mentioned in 80% of cases, and top choice in 70%.
(b) was a second choice in 30% of cases and mentioned in 35%.
(c) was mentioned in 65% of responses and top choice in 30%.
The educational portion of our initiative was seen as the lowest value. We are floating the idea of replacing the Education goal with a separate Justice goal, which is composed of letter-writing and other advocacy to help speed up any potential criminal investigations.
What bothers you most about Canadian cryptocurrency exchanges?
The responses varied widely. Here's a selection:
- "The lack of unbiased information on how trustworthy exchanges are."
- "The lack of transparency."
- "that they are unregulated"
- "I only use a non-custodial exchange now (Bull Bitcoin). The inertia and apathy of the government bothers me a lot. After Quadriga there should have been an inquiry. Even my emails to MPs Marie-France Lalonde and Bill Blair got no response. It's not realistic to wait for exchanges to 'self-regulate'."
- "Terrible for trading and unreliable"
- "Where is the regulation and oversight?"
- "It's difficult to know which one is safe and w[h]ich one is not. It's easier to go to a bigger exchange (eg. Binance, Kraken, ... ) who has a solid reputation than Canadian one (at least for now)"
- "Slow volume, difficulty to access for some, security"
- "Security, trust, support, education"
There is clearly a lack of satisfaction.
Should preventing events like Quadriga focus more on regulatory reform (working with regulators) or trying to create change through setting the example on one exchange and go from there (similar to how "Tesla" has electrified vehicles)?
- 40% of respondents desired an approach which included both aspects.
- 40% of respondents desired an approach of setting an example in one exchange.
- 20% preferred a regulatory approach.
- "(c), creating an independent classification/review system that would allow users to know which exchanges are most trustworthy, and to force less trustworthy ones to shape up."
- There are a few such services out there. Key issues are that these opinions can be influenced by referral bonuses, the exchange reputations change over time (as was the case in Quadriga), and there is limited information on which to base the evaluation. Many reputable third parties have recommended shady services that subsequently failed.
Pressing forward on both fronts appears to make the most sense.
Would you rather have the recovery run inside of a for-profit exchange (sort of a marketing/promotion idea to push people onto a safer exchange) or as an independent group of affected users pushing for our own interests (working with the safer exchange and other businesses potentially similar to a labour union or political advocacy)?
The end result:
- The majority (55%) prefer to have the independent group advocating for affected users.
- A minority (35%) prefer to have it run in a for-profit/promotional way inside the exchange.
- There were 10% of responses indicating both would be acceptable, or no clear preference.
We will be working to run this independently, however working closely with our partner exchange as a joint project (and it is definitely a promotional tool for them).
If given the choice, would you prefer (a) $20 cash each year for 10 years (slower recovery with full choice), or (b) your choice of $200 worth of discounts on products/services that are donated by small businesses which you could use this year (faster recovery with less choices)?
60% indicated a preference for (b), and 40% had the preference for (a). There is clear interest in focusing on both, which will push the fastest and most flexible recovery.
Affected users have a liquidation option which allows non-victims to purchase their tokens on the exchange. How do you feel about charging non-victims a small fee (5 cents per token) that is split between funding the project and a pool for affected user payout?
50% expressed outright support for the idea. Below are more detailed responses and comments:
- "indifferent, although I think any fee will end up factoring in to the exchange rate on the value of the token. If people are willing to pay $10 for a $15 coupon, then a 5% fee might mean they'll only pay $9.50"
- This is undoubtedly true. In your example, 25 cents would go to the project, 25 cents to affected users, and $9.50 to the seller. As opposed to $10 going to the seller.
- "I am not yet clear on the cost structure of the proposed solution. Has the cost of managing the recovery effort been accounted for?"
- It hasn't been properly accounted for, and this is one possible solution.
- "I think that it is more important to have broad communication, reaching out to public at large and crypto communities in other countries. Then there should be multiple ways for different communities to contribute financially to affected users. I don't like the idea of fees and tokens because it seems to distract from the larger tasks of communication, rallying, documenting and advocating."
- You bring up great points. Outreach is important, as is flexibility in approach. If you have more concrete ideas we would love to consider them!
- "Good idea, but it restricts the on boarding of new users"
- This is a fair point. The hope is that those participating want to help.
- "I would prefer to avoid this option, Unless we can show that there are many added benefits from using this platform over others, thus justifying the fees and making it more acceptable to users."
- Absolutely. Hopefully there will be many added benefits.
- "I think it a good idea, fees will go anyway to affected users, I totally agree"
- Awesome. That's definitely the intent.
- "better not tax when tokens are transferred to the blockchain - tax the transaction (something small, in order not to affect the volume/liquidity too much) like what they are doing with the flight tickets in Quebec"
- Absolutely! This would be a transaction cost only.
At the moment this has not yet been agreed upon by the partner exchange.
Have you discussed the project with anyone else who lost funds in Quadriga? What kind of feedback are you hearing?
40% said they've discussed it. 40% have not. 20% didn't answer (or it was hard to understand). Some of the responses:
- "only online, and there there seems to be some confusion about the projects goals, some concerns about the connection to a for-profit exchange, and a general 'one bitten twice shy' mentality."
- "Yes, Matt and my spouse. The problem was foreseeable. We just all ignored the risk because we were sold on the simplicity. The first red flag I saw was that accounts could be reloaded through an entity in China, which did not make sense, but I ignored it because of my perceived impression of protection given that the operator was in Canada."
- "Yes - most have given up hope of recovering funds"
- " I can't follow the chats on Telegram. I gained no knowledge the times I tried to read the discussions there. In fact the discussions there seemed to be not very polite. I wasn't able to connect with any other affected user. I wish there were some more structured gathering. Maybe a webinar would be nice."
- Note: This sounds like it may be talking about the separate and more popular Quadriga Uncovered Telegram group. We would be very interested for any examples of impolite discussions on our Telegram group.
- "This recovery process started out fine, but has turned into a circus show as is usual with lawyers who naturally want to stretch cases out to steal more money from victims."
- "Not for now, I don't know any other victim (except members of Quadriga initiative)"
- "Its your fault for keeping it on an exchange, what did you think was going to happen. There will be no money left after the 'bankruptcy'.. Lightning will solve all these problems other than recovery of funds."
Many affected users have strong privacy concerns and shame regarding what happened to them, such that they are even hesitant to share basic details. What do you feel is the best way to build trust and openness among the affected user community?
Here are some of the replies:
- "I really don't know. Keeping things as anonymous as possible might help, but then the project would also need accountability to show that most of the tokens weren't sent to your own account. It's a tricky problem."
- Absolutely. We also need to consider the various ways the project could be defrauded.
- "What you are doing now. I am just not clear on the sustainab[i]lility of this effort without appropriate financial support."
- "We all lost. We got burned. No shame in getting burned. It happens."
- "There must be a way for affected users to connect to each other. Communication is the foundation, and it can be done preserving privacy. Some ideas include a webinar, chat tools that preserve privacy, etc. I heard of the documentary but I don't know what will be there. I think it is important also for the public at large to know how Quadriga affected users. That is, it's important for some personal stories to be published, ideally in the mainstream press."
- We have Telegram, Reddit, and Twitter. A webinar would be great! There have been a number of mainstream news articles on Quadriga, although it's not well known outside of the crypto community. We welcome any further ideas for platforms.
- "I would use the angle that crypto will continue to gain traction as time goes on, and that although the affected users were victims of a terrible fraud, we have an opportunity to prevent this from happening to others. I would also use the fact that this initiative has gained a considerable following and that affected users are all in this together, whether we want it or not."
- "Maybe a guarantee that nobody will be further persecuted would help."
- Hopefully no affected users are persecuted. Who's being persecuted?
- "I don't know what else could be done for now."
- "Just let us go forward."
- "Once you demonstrate positive effects (and communicating about them), and set up ways to contact you securely, the users who have privacy concerns will contact you. You should have anonymous way to communicate with you (maybe using memo.cash?)"
- Feel free to use an anonymous handle for any communication with us via Reddit, Twitter, Telegram, or email.
- "Simple questions, good job :). Wonder about the stages of loss/gr[ie]f. Maybe the stinging pain needs to subside before people will trust."
Notes: Percentages rounded to the nearest 5%.
Thank you very much for everyone who took the time to respond! We will continue to study your answers as we move forward!
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