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've taken the liberty of rounding up all the questions and answers provided from Hydro's most recent AMA hosted with BitcoinMarkets incase you missed it. Enjoy! Hydro Q&A’s Q (knonsu):
How does Snowflake relate to other identity protocols out there like Civic and uPort ? A.1 (Anurag):
We see snowflake as existing a layer below these types of projects. Even without blockchain, identity is a broad term. Different people around the world have different forms of identity (state ID, country ID, social media IDs, etc). Civic, uPort, and other blockchain projects help to build specific types of an on-chain identity for a user; however those IDs are meaningful in different ways to different observers. For instance, imagine that a government or business builds a system that accepts Civic as a form of identity while another government/business only recognizes uPort identities. On top of this, certain systems only care about information tied to a user’s social media profile. A user can maintain one standard Snowflake as a base layer and set each of these different forms of identity as a resolver. Snowflake eliminates the need for global unanimous adoption of a singular identity standard and rather allows systems to build business logic off of identity standards they themselves recognize. Follow up Q (knonsu):
thats cool. so its totally depends on the person/ institute utilizing it . One problem I found is how easy its to create fake identities (in their basic system). A.2 (Anurag):
Yup! So people can conduct off-chain verifications to prove that you own a snowflake, and then tie an on-chain verification to your Snowflake. This links real-world KYC to your on-chain ID, so sure you could mint another snowflake, but that same party won't validate it again for you. Anyone who trusts that party would be able to accept their validations, and people who don't trust that party can rely on a different validator they do trust.
— Q (kat):
How big is the team working specifically on Hydro products? Can we get a numbers breakdown of engineers, biz dev, etc? Do you have plans to scale this team as the Hydro project develops? A.1 (Andy):
Our Hydro team is 8 people.
Devlopers (Myself and Noah)
Product (Anurag and Shane)
Founders (Mike and Matt)
The nice thing about Hydrogen though is we have a team of 30 people who we can leverage for different things. For example, Noah and I do not build mobile apps, but we have a front end team that is well versed in mobile app development. So while they are not directly on the Hydro team they do have a direct impact on Hydro.
Hydrogen as a company is working to grow pretty rapidly. As we grow we will be filling out more positions in both blockchain and non-blockchain rolls. A.2 (Anurag):
To add to Andy's answer - pretty much everyone working for Hydrogen helps out with Hydro in some way, whether via design, front-end development, API support, business discussion, etc.
Here's our full team: https://www.hydrogenplatform.com/about
— Q (rocket man):
So in the age of ICOs, what motivated your team to not pursue that funding model and instead have a token distribution for developers? A (Andy):
This was something that we spent a very long time considering and discussing. We spent a lot of resources (time, money & energy) trying to find the best solution for us going forward. When it was all said and done, we decided on an airdrop because of two main things, getting the token into the hands of people who will actually use it and regulatory concerns.
We feel as though our distribution was the fairest approach that allowed for people with actual interest in the Hydro community to get involved. Overall, we have been very pleased with the level of community engagement from people who are interested in the utility of the Hydro token and we feel that a lot of this can be credited to our distribution strategy.
— Q (matheussiq8):
How hydro tokens will be used is still vague in the Snowflake whitepaper draft. Would the amount required to hold depend on the volume of API calls or some other parameter? For example, if I decide to implement raindrop and later snowflake in my small webshop would I need to hold the same amount of tokens as Binance (if they ever implement it of course…)? A (Noah):
as always, the permissionlessness of public blockchains is a double-edged sword. smart contracts partially solve the problem by letting us enforce certain things on-chain (minimum token balances, signature validity, etc.), but there are limits. so, re. your specific question: in raindrop we do not vary the staking requirement across users, because that would necessarily involve value judgements we are not comfortable making as a centralized entity. however, there are two types of staking required for raindrop:
- “institutional staking” requires entities who wish to sign up raindrop users *on their behalf* (i.e. passing new users’ addresses to the smart contract as parameters rather than new users transacting directly from their accounts) to stake a significant amount of hydro. these are the players we want to ensure are acting in the best interests of the community. in this model, hydro is simply one of many institutional stakers (where we sign up users on our kickass mobile app, which will be out soon).
- “user staking” requires individuals who wish to sign up for raindrop on their own, i.e. transact directly with the smart contract, are able to do so by staking a much smaller amount of hydro.
What this all means for you, as a potential customer of our API, is that you don’t actually have to worry about the staking requirement or signing up users at all, and can simply use our API in conjunction with the Hydro app.
Looking ahead to Snowflake, we have big plans to integrate increasing sophisticated uses of the token into the product. to some extent these are still up in the air, but rest assured that we are very focused on building a strong tokenomics structure. At a high level, the core token mechanism for snowflake will involve depositing tokens into the snowflake smart contract. These deposits will allow native staking/payment/incentive functionality denominated in hydro, without the hassle and worry of using ether with every call.
— Q (Hodlall):
When is raindrop Android app is releasing A (Andy):
It is currently under development. We have a bunch of android phones with different OS on the way. It is hard to give a set date as we don't know what unforeseen issues could come up during the process though. All I can say is it is literally all that our mobile development team is working on
— Q (Jeff_We_Cannafi):
To piggyback on matheussiq8’s question, how do these identity tokens compare to existing forms of identity authentication, and do you anticipate the tokens themselves will be traded on exchanges? A (Andy):
In my opinion, the main difference between what we are working towards and others like civic and uport is the scope of what we are aiming to do. We understand the value of having KYC on the blockchain and "One click signup", but really I think blockchain identity can be so much more than that. We are aiming to create a completely extendable and modular protocol which will allow for people to link anything they desire to their blockchain identity. Other protocols can tend to lean towards centralization (more a fault of current KYC procedures than the projects themselves) and we feel like this doesn't have to be the case. At least for now, something like KYC needs to have central authorities to verify user information, but why can't I also link my crypto kitties to my blockchain id or my linkedin profile to my blockchain id?
Overall, what we are trying to build will easily allow for other blockchain developers to create robust identity solutions for whatever application they feel fit with Snowflake being at the core of that. We feel that this is crucial to eventually creating a completely open and decentralized identity system. Anyone can join and anyone can add what THEY consider to be an identity, but I only have to accept what I consider to be an identity.
As far as trading, Snowflake Identity tokens will never be tradable. We feel that you identity should always be linked to you. This would be a dangerous road to a very easy black market for people's identities
— Q (Jrock):
What do you find the hardest part of pitching icos to regular companies?
Also what do you think needs to happen for widespread crypto adoption? A (Shane):
If you mean pitching Hydro to regular companies (we're not an ICO :stuck_out_tongue:), I would say the hardest part is getting the larger companies to move faster than a snail's pace. There are too many chefs in the kitchen and sometimes there is a lack of top-down strategy on blockchain, and it leaves large enterprises paralyzed sometimes. We try to resolve this by pitching how easy Hydro is to use, and how it connects to our broader Hydrogen ecosystem which can add value in a lot of places.
In my opinion, widespread crypto adoption is going to be dependent on how parallelization plays out. If crypto's only option is to create a new parallel economy, widespread adoption is going to be slow and arduous and will take decades. However, if blockchain is able to be infused or layered on some of the current systems we have in place, the adoption will be much faster and broader. Ultimately this comes down to the usage of private vs public chains - the more private and centralized chains that get implemented, the farther the mainstream adoption will get pushed out.
— Q (Luke):
One aspect of Hydro that is beginning to really intrigue me are the potential use cases and dapps that can be built by external developers ontop of the Hydro protocol layers for each phase.
- Having held various dev meetups and networking at various conferences, how are you finding the process of attracting developers to start building dapps and products in your ecosystem?
- I understand the HCDP is getting updated with various new rules and bounties for dapps to be built, have you approached any developers yet with this new offer, and if so, how has the reception been?
- How else do you intend to attract developers towards building on the Hydro protocols?
- Through our events, we're mainly focused on helping expand the blockchain-focused developer community. We help give exposure to projects we find to be doing neat, innovative work in the space and keep ongoing dialogue with these communities.
- In particular, to provide impetus to developers in the Hydro ecosystem, we've established the HCDP. The new process will involve putting out specific task requests. In the next week or so we'll have published specifications for dApps that can be built on top of Snowflake. We ourselves will not be building these dApps (they have nothing to do with Hydrogen's space as a company). This helps the ecosystem expand outside of Hydrogen-specific use-cases.
- ^^Through the above process to get them started. Eventually, we want the Hydro development process to be community-driven, so people are building on Hydro because it benefits their own programs and applications.
— Q (elmer_FUD):
Hey Hydro Team! Here's a few question I've got for you after checking out the Raindrop and Snowflake whitepapers:
How has your experience working in the Ethereum ecosystem been so far?
While you are currently focused on the financial sector, would you consider actively marketing to other sectors such as healthcare and education in the future?
It seems like both Raindrop and Snowflake would be useful in any environment that processes or stores sensitive data.
Do you have plans to release official Raindrop SDK packages in other languages in the future?
A bit more of a specific question: Raindrop is looks like a great product to use in a PCI-DSS environment - do you have thoughts on whether or not it the product is ready for primetime and do you think the industry standards and government regulation is prepared to handle these kinds of systems? A (Andy):
Thanks for the questions! I'm gonna answer each in a separate response in this thread
Overall it has been pretty solid. There is still a ton of room for growth in terms of documentation and stuff like that, but it is miles ahead of basically every other blockchain platform I have worked with. By far the biggest pain has been handling gas costs when considering the user experience. When trying to build actual products that people will want to use we feel that making it user friendly is something that many blockchain projects have not focused on nearly enough.
Yeah certainly. We focus on fintech as that is where the rest of our companies APIs focus and that is where we have the most connections, but much of what we are building is much further reaching than that. Just as far as authentication goes, it really can apply to any major field and we intend to market it as such.
We currently have Python and JS SDKs and have had a few java ones submitted through our community dev program. We have been revamping that program, but I anticipate we will be putting up more bounties for most major languages. I have considered making a few more myself, but we feel that they could be better suited as community projects.
I completely agree. Raindrop and blockchain authentication when handling anything around payments is a great application. I think the biggest thing is actually convincing regulatory bodies that the protocols we have build are secure (since many can still be scared of blockchain). I definitely see this as a direct use case though
— Q.1 (khonsu):
What kind of banking relations do you have as a company, do they (banks) understand what you are trying to do ? Any VCs approached you for funding ? explain your business model. A.1 (Shane):
Hydrogen has existed since 2009 in the form of Hedgeable. Hedgeable is a consumer-facing online investing app, and the tech behind it eventually spawned the Hydrogen tech platform. The story of how the transition happened goes essentially like this: (1) Hedgeable was disrupting banks & investing firms, (2) banks & investing firms started contacting us and seeing if we would help them digitize & automate their own businesses, (3) we started packaging up our tech and selling it to the banks. There was so much demand for this from financial institutions that we spun out a new company (Hydrogen).
So to get back to your original question: we have some long-standing relationships in the banking & finance world, and to this day we have inbound leads from that space coming in every week. The key thing to keep in mind is that these institutions move extremely slowly, but they do understand the core value prop of our platform. Many of these firms are still in the midst of basic digitization efforts (i.e. moving from really slow offline processes to simple digital infrastructure), and that is the primary thing we are helping them with in early stages. But they are also keen on blockchain tech and they will naturally turn to us for that once they reach that point. We do have a few relationships with big financial companies in which Hydro/blockchain are already part of the discussion.
We have revenue and don't need to rely on VCs. It is our general philosophy that building a business sustainably with actual clients and revenue is a good approach, but we would consider working with the right VC if that came to be and we wanted to scale more quickly. Right now, that is not an immediate concern for us.
Our business model is in charging developers and enterprises to access the Hydrogen technology platform, which currently consists of products like Atom, Ion, and Hydro. Developers pay a per-user fee to hit our core APIs, while large enterprises negotiate custom (usually multi-year) contracts with us that typically include recurring revenue. Hydro, specifically, is being offered for free right now, as we attempt to gain adoption. But it is important to note that Hydro is just one piece of our ecosystem. Q.2 (Joleen):
When you say fee - is this fee HYDRO? And when do you envisage HYDRO to no longer be offered FOC? A
**.2 (Shane):** Sorry if it wasn't clear, I meant free to use our Hydro tech/APIs. The usage of HYDRO tokens within that is a separate issue - they still need to have HYDRO and we do not give it away for free to clients
— Q (guacam0le):
Adoption of an identity management solution (etc) would potentially involve a lot of identities. Further, scalability is a hot topic w/ blockchain. Is this a potential bottleneck? What is or might be done to address such?
Tackling a competitor like Google or Authy's 2FA is no small feat. Also, not everyone is yet to embrace blockchain-based solutions. Have you found it difficult to interface with enterprises & get them excited about the idea of an overhaul? A (Anurag):
nowflake is designed to be relatively low-load on the blockchain. A user needs to conduct a single transaction to “mint” their Snowflake. Once this is complete, they would need to complete one-time transactions to set each of their different forms of identities as resolvers as needed. A Snowflake is designed to be built out via resolvers over the duration of a user’s lifetime, so there’s never a need for heavy, frequent transactional capability. Similarly, smart contracts simply need to be set as resolvers by users; they do not themselves transact. Network scalability improvements will increase the range of use-cases for smart contracts that can be tied to Snowflake, but they aren’t a necessary prerequisite to some important early use-cases such as KYC platforms, and a few basic user-interaction platforms.
As far as competition, we feel that current adoption of 2FA is, in general far short of where it should be, and any 2FA is generally better than none. Many businesses use text-message based 2FA, etc. In the short-run we are aiming toward pilot implementations with small businesses. To further this, we have put out many integration resources, guides, and documentation and accordingly believe implementation of Raindrop is a more straightforward workflow. As far as large enterprises go, Hydrogen has clients, so it is helpful for our project to have those connections. Large institutions are generally relatively slow-moving, but have expressed interest in using Raindrop, in particular for securing employee accounts. As the product grows, we may eventually move in this direction with Client Raindrop, but resources will always be available for any site that wants to adopt it. Additionally, we are looking into making a wordpress plug-in to make implementation much more accessible for many developers.
-- Q (Smithymethods):
I know Hydro is a fintech company, hydro plan to curb phishing and hacking to the bearest minimum we know that hacking is very rampant these days on MEW and with other wallet. Is Hydro planning to create a wallet that support hydro and other tokens using their raindrop Technology?
As this will put an end to the problem of phishing and also promote hydro A (Noah):
like everyone in the crypto space, we’re very worried about phishing, both personally and on behalf of all hydro token holders. we first want to reemphasize that preventing scams and fraud has to be a community-driven effort: teams and users need to be vigilant and promote best practices (never trusting links in public chats, shunning fake accounts, etc.). we are excited about raindrop’s potential to help combat phishing, though. we actually talked with someone about mycrypto about integrating raindrop into their desktop app. we’ve forked their code and are researching how feasible an implementation would be, stay tuned for updates!
— Q (Hodlall):
What security measures in place for hydro , I see lot of tokens being hacked nowadays , and money is stolen.. how does hydro make sure their team tokens are completely secured or as much as possible A (Andy):
We all have been in crypto for a while and are pretty well versed in securing our stuff. Our tokens that are currently locked are in cold storage. Others are held in hardware wallets
— Q (Joleen):
We know that the Hydrogen platform is going to be used by CI Investments, a large insurance firm and a world top 20 bank, have these companies already begun purchasing Hydro OTC? A (Andy):
This is something that we feel is best to be hands off with. It is really up to the discretion of our partners
— Q (khonsu’s mumaffi):
Ill be honest i have not yet fully read the whitepaper but id like to know other than investor growth do you truly believe there is interest in a model where users have to pay each time for access? How big do u expect this fee to be...for large companies dont you believe this is an unscalable practice? This may be a question more about most technologies built on token based economics too. A (Andy):
So we have 2 different authentication protocols. One happens less often and is in the same vein as OAuth. This is called Server-Side Raindrop. This requires tokens to be sent. This protocol would only happen once per day for a business when accessing something like an API. I don't feel that these values are extremely high for increased security.
Our second protocol, Client-Side Raindrop, functions much more like google auth. This logic actually does not require any tokens or even a transaction by the end user. It is 100% free for them to use and they will never have to pay for a transaction. Here the responsibility is on the implementing party to stake tokens. This allows them to onboard users and authenticate them.
We felt it was crucial to have an authentication that did not have a cost per user login as it is not scalable
— Q (khonsu’s mumaffi):
Also do u plan to tokenise atom and ion too and if not covered earlier how big of an impact do the market conditions have on your business A (Anurag):
Tough to say we're going to "tokenize" them since that word can carry a lot of different meanings in different contexts, but we do plan on integrating the entire Hydrogen platform with Hydro. This will most likely take the form of enhancements to systems leveraging Hydro. You can find a more detailed breakdown on our Hydro roadmap: https://medium.com/hydrogen-api/project-hydro-features-in-depth-look-39faa29f0d61
Market conditions don't really have an impact - we're still building the same tech on a day-to-day basis
— Q (ghost):
As a company in the space, do you see the fact that tokens have to be acquired on exchanges as an issue? How would a company that wants to develop with you acquire tokens? A (Anurag):
Depends on what they're developing. dApps developing using Hydro smart contracts to create native functionality to their applications would need to acquire those tokens on their own; however, companies using the Hydrogen API will not. Here's a detailed article outlining when a developer would need the token for the Client Raindrop smart contract: https://medium.com/hydrogen-api/how-to-use-client-raindrop-without-using-the-hydrogen-api-bb04934ae293
— Q (jarederaj):
Can you describe your stakeholders and give me a better sense of the exigency of your products? Who are you focused on serving with your platform and why are they motivated to use your platform? A (Shane):
The Hydrogen platform serves developers and enterprises who want to build applications. We are specifically targeting the financial services sector, including banks, investing firms, insurance providers, and financial advisors. This includes large enterprises, individual developers, and startups.
Our products are Atom (core digital infrastructure & engine for finserv), Ion (AutoML & business intelligence capabilities), and Hydro (blockchain & decentralization layer). Each has a different use case but these products combine to form an ecosystem of tools for developers to build sophisticated applications with.
The main pain point we are addressing is the resources required to build, launch, and run a digital financial application. These resources include both time and money.
Large enterprises have resources, but they waste years and millions of dollars trying to launch digital platforms (we've seen this first-hand), often unsuccessfully. The motivation here is obvious. Startups and smaller developers, on the other hand, do not have access to huge resource pools, so they are forced to look for solutions that make the process more efficient.
In the same way that Wordpress makes launching a blog easy and also allows for extended functionality, Hydrogen makes launching fintech application easy.
— Q (shujjishah):
When the app will be released??? A (Anurag):
We're going through our mobile development very iteratively. Since we work very closely with the product, there are things we can't recognize until we've got people beta testing the app. As we started Beta testing and conducting user-research, we realized that one aspect of the UI for the app was not intuitive to about half of our testers. We decided to make a few API changes to enable the mobile app to display a "linked" vs "unlinked" status in order to improve the user experience. Our front-end team is finalizing these changes, so our Beta testers will receive a new build in their testflight apps within the next few days. This new build will require another round of Beta testing to ensure that none of the code changes causes any problems on devices; if this change goes smoothly, and our mainnet testing goes smoothly, we will be able to release the app this month.
Since there isn't much precedent on releasing a product into the app store that connects users with the ethereum mainnet, our primary concern is making sure the product works fully as intended and provides an intuitive user experience. Misc Q&A’s Q (elmer_FUD):
What's your favorite thing to drink? A.1 (Andy):
Overall, I really love Baja Blast Mountain Dew. If I am drinking, I'm a big fan of fruity beers like Blue Moon and Shocktop. Also had a really good raspberry sour recently A.2 (Nahom):
Primary=water but i do enjoy Jamaican ginger ale/beer. We keep honest tea in the office too, i love it because it brings me back from the dead:skull_and_crossbones:, @Hydro Andy drinks most of it behind my back though :triumph: A.3 (Noah):
hard: tequila or picklebacks
soft: any sour beer
other: mango juice
i also crush like 2 nalgene’s worth of water every day at work A.4 (Shane):
For hard alcohol: whiskey/bourbon A.5 (Anurag):
ooh, went to the finback brewery last weekend; was wonderful
— Q (Joleen):
Do you HODL any other tokens personally? A.1 (Andy):
I do. I think it is probably best to not say which, but if you follow me enough in #altcoins I am sure you will see me talk about a few A.2 (Noah):
im a bit of an eth maximalist actually :grimacing: i do dabble though
— Q (Joleen):
Who got who in the World Cup sweepstakes? A.1 (Andy):
I'm going for Germany, but I know next to nothing about soccer A.2 (Shane):
I'm rooting for Portugal, but I don't think they're going to win the cup
— Q (Joleen):
Who's got the best banter in the office? And who has the worst? A.1 (Andy):
One of our backend devs, Paavan, typically has some great banter
and even better hot takes A.2 (Noah):
dont @ me for worst banter A.3 (Shane):
Sabih (BA @ Hydrogen) banter is by far the best
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