Circle has still not responded to Peter Todd about whether they are implementing censorship or surveillance technology
so let me summarise, mike hearn is a developer that has been pushing for blacklists, censorship, supporting regulation .etc he is a crony in the worst way. peter todd is the developer who has done loads for bitcoin. the anonymity techniques in dark wallet were invented by him. he works for the people. mike hearn wants to censor peter todd. https://bitcointalk.org/index.php?topic=418071.msg6412027#msg6412027 circle is a new company that is always promoted by the foundation and their crew of people. they always appear at the top of conference lists for finance .etc http://bitcoin2014.com/http://www.bitfin.com/ jeremy allaire (circle ceo), makes statements that bitcoin needs to abandon its libertarian roots. we need to take this plaything away from the anarchists kind of attitude. http://www.coindesk.com/bitcoin-abandons-anti-establishment-wall-street/ mike hearn is working with circle: http://www.coindesk.com/circle-advisory-board-members-burns-appointment/ circle is working on tracking and surveillance tech: https://bitcointalk.org/index.php?topic=418071.msg6403720#msg6403720 they refuse to answer questions (this is one of many, can't find the rest): http://www.reddit.com/Bitcoin/comments/25ou9f/good_morning_reddit_we_know_youve_been_wondering/ mike hearn says the bitcoin dev model needs to change. backing up gavin (chief scientist of bitcoin foundation who is actually more like a figurehead to legitimise the foundation)... this is his way of pushing out elements by formalising the dev process to stop people to participate and take control. http://www.reddit.com/Bitcoin/comments/28zts3/mike_hearn_interview_quotes_progress_on_the/ circle also this month made a similar statement (on coindesk): http://www.coindesk.com/circle-ceo-jeremy-allaire-issues-challenge-bitcoins-core-developers/ note how he says "unwelcoming to new participants" - same words as mike hearn. if you want to dev bitcoin, there's nothing stopping you. go write code or participate. don't try to assert control. it's all related, bitcoin foundation being official with their claim to legimitimacy but no merit to back that up. https://bitcointalk.org/index.php?topic=322328.msg3460051#msg3460051 "Just got a call from the bitcoin foundation. They wouldn't go on the record to comment on the article but just kept telling me "off the record" that you lot [Dark Wallet] have no credibility and that a much better story is some venture capitalist yesterday investing $9m in bitcoin..." ~email from journalist when we were doing DarkWallet crowdfunding. btw check this, http://www.reddit.com/Bitcoin/comments/2646ei/bitcoin_foundation_has_4600000_in_assets_90_in/ and despite all those resources they have done jack shit for bitcoin. there is some big corruption going on here. foundation people are all flying all-expense paid fancy trips, paying themselves high salaries whilst most wallet developers and the opensource projects (which people use) in this space are without resources. they have contributed nothing to the community. there's been no proof otherwise besides some minor grants for ~$10k or so. http://www.reddit.com/Bitcoin/comments/2aycxs/hi_this_is_ben_lawsky_at_nydfs_here_are_the/ people are like "oh dear, we need better legislation" without realising the foot in the door danger. it's like the used car salesman who rips you off with an overpriced crappy car which you jump on after "he speaks to the boss" (i.e smokes a ciggy), knocking down his initial high offer. wow! what a bargain! G8 magazine, June 2013 "Protecting digital economies": "If the leaders of the European Union and United States could be convinced to take a lead on these initiatives [banning Bitcoin], that would be a huge contribution to making the internet a safe place for financial transactions. At the same time, it would also strike a blow against those who would try to destroy the fabric of our world’s well-being." JP Morgan, Feb 2014 "The audacity of Bitcoin": "But followers of financial history know the limitation of a system based on a fixed or slow-growing money supply: it imposes uncomfortable financial discipline on governments, households and corporates. [i.e governments, consumers, the corporations" (goes on to talk about how printing dollars was used to fund WW1 and the Vietnam war as a good thing) ECB, Oct 2012 "Virtual currency schemes": "Authorities need to consider whether they intend to formalise or acknowledge and regulate these schemes. In this regard, a likely suggestion could sooner or later involve virtual currency scheme owners registering as financial institutions with their local regulating authorities. This is a similar trajectory to the one PayPal has undergone, as it was granted a banking licence in Luxembourg in 2007 after its service became popular. This is not an easy step, but it looks like the only possible way to strike a proper balance between money and payment innovations on the one hand, and consumer protection and financial stability, on the other." Mark my words. The problem is not with this regulation needing to be fixed. They will probably tone down the proposal and it will be hailed as a victory within the community, yet be another step toward normalisation of their activities. http://www.coindesk.com/ben-lawsky-friend-foe/ "The choice for the regulators is: permit money laundering on the one hand, or permit innovation on the other, and we’re always going to choose squelching the money laundering first. It’s not worth it to society to allow money laundering and all of the things it facilitates to persist in order to permit 1000 flowers to bloom on the innovation side.” ~ Ben Lawsky funny he's affiliated with chuck schumer too who is a populist and someone who in the early days was very anti-bitcoin (silk road). i love the whole tone of this propaganda piece which is like "he's such a nice guy". I bet he has good manners too. maybe you all appreciate this article, http://motherboard.vice.com/read/the-dark-wallet-developers-plan-for-startup-governments-run-on-bitcoin
Aug - Oct 2010 preceded a runup from $0.06ish to $1.
In neither of these charts will you see a prolonged stable period followed by a drop in price. History never repeats itself exactly, but the dynamics of widespread adoption, innovation, incentives to profit, and media hype have not changed much. What has changed is that we're finally coming up squarely against the specter of regulation, and directly challenging the livelihood of powerful organizations. If you believe that bitcoin can continue to grow quickly and innovate (somewhere) in spite of these perceived threats, then you might not have a hard time believing that we may see yet another bitcoin hype/price spurt.
Dear Ben Lawsky--Yesterday, Coinbase put something into the world that will protect more consumers than any regulations you could hope to enact
Dear Ben Lawsky, Yesterday, Coinbase put something into the world that will protect more consumers than any regulations you could hope to enact: multi-signature wallets. With multi-sig wallets, there’s no way the money deposited at Coinbase can be “Goxxed”. Nor can it be part of a fractional reserve system. Consumers’ deposits are under their control, not anyone else’s. This is something that’s possible with Bitcoin but not traditional money. Why did Coinbase create this service? After all, there was no regulation requiring them to do so. What motivation does Coinbase have to come up with a multi-sig wallet without a regulator cracking the whip? Well, they’re a business, and they want happy costumers. They want to make money and not worry about possibly going to jail. And customers want peace of mind knowing their Bitcoins cannot be lost in a Mt. Gox-style disaster. I know, I know—most businesses cannot be trusted to police themselves. But I submit they have a much greater incentive to protect customers than you do. If they do a poor job, they go out of business. Not every company will innovate, but get enough companies in the space and some of them surely will, and the others will have to keep up or go out of business. You see, in the Bitcoin space, the way to protect consumers is by innovation, not by regulations. We need an ecosystem of dozens of Coinbases. Yes, some will fail, and yes, along the way, some people will lose money. But that’s the type of environment in which best practices evolve. Let’s face it, the gauntlet has been thrown down: Circle had better come up with something fast to match Coinbase. No future online wallet startup could hope to compete without a multi-sig feature, and if they really want to steal customers, they’ll have to come up with something even better. So what should you do? What is your role? I submit that the best thing you can do is wait and watch. Let the next 5 years play out. Don’t rush in with hasty regulations based on the old system that harm competition and empower entrenched companies. In the Bitcoin world, consumer protection happens via evolution, not regulation.
So it's pretty evident now that Lawsky's motive was to appear as though he was trying to help us by making favorable regulations, but all the while his motives were to get close enough to the community in order to 1) gain acceptance among the community for his regulation, and 2) Better understand the intricacies of bitcoin, to ensure his legislation could be as comprehensive as possible. In his legislation, he makes mention of things that only a seasoned bitcoin enthusiast would know of. He used his intricate understanding of the different types of bitcoin services that exist, only to make sure his legislation covered EVERYTHING. Even decentralized wallets. Even the very creation of cryptocurrencies themselves. I hope we can all learn from this, and never fall for the "friendly bureaucrat" trick again... even if they do an AMA while holding a super nintendo controller.
My thoughts on Ben Lawsky's proposal from the point of view of a startup with no funding
EDIT: http://en.wikipedia.org/wiki/Safe_deposit_box When you store money in a safety deposit box essentially, you, the bank and the government have signature on the box. With the government having final say on seizing the funds. EDIT: Are we actually securing virtual currency?- i'm not so sure. Our users backup one of their keys offline and hold the password to decrypt the other one. essentially, THEY are securing it. So, Ninki Wallet enters alpha testing then, this bomb drops:
(n) Virtual Currency Business Activity means the conduct of any one of the following types of activities involving New York or a New York Resident: (1) receiving Virtual Currency for transmission or transmitting the same; (2) securing, storing, holding, or maintaining custody or control of Virtual Currency on behalf of others; (3) buying and selling Virtual Currency as a customer business; (4) performing retail conversion services, including the conversion or exchange of Fiat Currency or other value into Virtual Currency, the conversion or exchange of Virtual Currency into Fiat Currency or other value, or the conversion or exchange of one form of Virtual Currency into another form of Virtual Currency; or (5) controlling, administering, or issuing a Virtual Currency.
In the development of Ninki Wallet we wanted to bring a new level of security and usability to Bitcoin, we decided on a 2 of 3 multi-signature architecture in order to give the user of the wallet ultimate control, provide a layer of services ourselves via countersigning and at the same time limit our exposure in the event of a server hack, ie. even if they get our key, they can't spend our user's funds. Under the definitions proposed by Mr. Lawsky
(2) securing, storing, holding, or maintaining custody or control of Virtual Currency on behalf of others;
I am not 100% sure, but it does appear we fall into the above category, as do other web wallets Storing: we technically store 2 of the 3 private keys but can only access one. The other is AES256 encrypted by the user's password via a salted pbkdf2 and using a CSPRNG to generate the IV for the encryption itself. ie. from our point of view we are storing nothing! Question: Is storing encrypted data the same as storing data? Are we actually storing virtual currency? Securing: We are definitely securing virtual currency Transmitting: We countersign the transactions and broadcast them to the Bitcoin network, we are definitely transmitting. It appears we need a Bitlicense, even if one of our users in Japan sends Bitcoin to a user in New York, we are in breach of these regulations. Given our wallet can send and receive to/from external Bitcoin addresses, how can we possibly ever comply! Someone sets up a wallet account, provides their address and ID, full compliance etc., then someone sends them money from a Bitcoin qt client running in NY which is received in our wallet, we are in breach! So, where to go from here: Option 1: Exclude US IP addresses altogether Users can always use VPN to use our service. All it would take is one incident of a NY user using our site, and we are in breach. Option 2: Try and comply. The demands are way too much for what is essentially a project that aspires to develop into something bigger, we are not in a position to appoint compliance officers etc. I mean, get real! Some of the demands could be automated quite easily, things like reporting transactions over $10,000 involving a NY resident, however we then need to take an address and ID from every user who joins our site- just to prove they don't live in NY! We are not in a position to do that, i mean, think about the logistics there. All kinds of ID from all over the world. Option 3: Give up. Not an option. Also, I guess once these come into effect, blockchain.info and other web wallets, bitgo etc. will be breaking the law as they currently don't ask for addreses/identification. Does anyone have any ideas?
Lawsky: regulator bat signal. Do not let exchanges naked short digital currencies. Four simple rules below...
For the uninitiated, short selling is when you borrow something from someone else and sell it, hoping to buy it back at a lower price to repay the lender of the item. This creates a credit risk because if you can't pay it back you default and the lender is not paid. Naked shorting is when an exchange allows you to "sell" a unit of something that you do not own and have not borrowed from someone else. It's essentially creating counterfeit units of account to sell, with the hope that you can buy the counterfeit units back at a lower price before anyone is the wiser. Lawsky, we do need regulation. Not of individuals, but exchanges. It's actually a pretty desperate situation. The thing could very easily go CDO and become a vehicle for fleecing the general public. Four simple rules: 1) the practice of naked shorting digital currencies is not permitted and is to be considered securities fraud. 2) shorting is allowed, but only if the holder of digital currency units on the exchange expressly authorizes the lending of units to parties that wish to borrow units for short selling. 3) holders of digital currency must have the option to not lend their units for short sale activities. Exchanges may charge or offer less favorable terms and fees for holders who decline to lend assets, but the option must be available. 4) at the close of each weekly trading period, exchanges must digitally sign for the addresses holding their digital currency assets and publish book sum of short and long holdings listed on their exchange. One and four are critical. The beauty of bitcoin is that everyone can see the ledger and private key holders can sign for balances securely. This includes signing for master private keys of exchanges use hierarchical deterministic wallets for internal pooled accounts. If we had this regulation with Mt. Gox the problems would have been public long before we learned about the fraud. It's also easy to do operationally, there is no reason exchanges cannot support these requirements. These rules will greatly reduce systemic risk and stop creative wallstreet derivative asset shenanigans. Those shenanigans all ride on the ability to create leverage from counterfeiting and creating credit risk. These derivative assets serve no purpose and out our economies at risk. Please do the right thing.
Hey all! GoodShibe here! I'm technically still on vacation, but in light of the news out of New York... I feel the need to comment. If you're not aware of what's going on, the New York State Department of Financial Services is proposing a new regulatory framework for how all Cryptocurrencies work for the residents of New York State. However, the way that it's worded, the way that it's been presented, it's incredibly vague in some areas while being incredibly strict in others. They're designed to take 'untraceable digital cash' and, at pretty much every point along the chain, put someone's face and name to who had what and when. This, of course, weakens Cryptos immediately in compared to, well, cold, hard cash -- which is largely untraceable. This bill, as it has been designed, seems to try and have a massive chilling effect on cryptocurrencies in general. You can use cryptos, sure, but by the time they're done with them... why would you want to? You can read the proposed Regulations here. AmericanBitcoin has put together a TL;DR of the proposed reglations goldcakes has put together a TL;DR of some of the ramifications If you'd like to see a quick breakdown of exactly what's wrong with the proposal, I highly recommend you read this comment by MrMadden over in /Bitcoin, which is utterly fantastic. dalovindj also has a great post on how this would effect our fellow Shibes. Here's the thing: We always knew that this was going to be a problem. The idea that somehow the old, established system would just roll over and let the next generation step up to the plate without a fight is laughable. And now we've seen the first volley. The warning shot off the port bow, so to speak. The regulations that are coming out are, well, typical government overreach designed, specifically, to elicit the reaction that they are. They're big and scary and over-reaching. But they're also designed so that, IF there's a public outcry, at a large enough scale, they can 'pull back' the more offensive over-steps and still come out of this with the regulation that they REALLY want. If nobody stands up to complain or fight back about it... then bonus for them. The city of New York then gets global over-reach on a massive scale all under the guise of 'protecting it's citizens'. Incidentally, if you hadn't noticed, Canada set the wheels in motion recently, with the first 'Bitcoin Law' which caused quite an uproar (remember when DogeDice closed down rather than meet the Canadian Government's new regulations?). Here's the thing - and it's a truth that's as immutable as time itself: Governments are going to Govern. They will always move to exact as much power as we let them have over any new or emerging technology, especially where money is involved. So... what can we do about it? For those who don't live in the US, the best thing you can do is learn about this regulation - because, whether you like it or not, the Government of the State of New York is making it your business. Because anyone who does business with residents of the State of New York will have to submit to these regulations as well. Meaning that if you do business with a business that does business with the state of New York, you will be subject to those same overreaches. The long and short of the problem is this: You have 45 days, starting on July 23rd, once the Regulations are formally published, to make a case to the people of New York that, whether they realize it or not, this bill is trampling their rights. Because, that's how you defeat this issue. We need to get NEW YORKERS to care about this issue. If you're not in New York, your job is now to find a way to help make New Yorkers care about this issue. I don't care which banner your coin flies - Bitcoin, Litecoin, Dogecoin, Reddcoin, Potcoin... this is effects us all and it's only just getting started. How will this bill effect them? It might not, directly, lots of people aren't using cryptos yet. But it's the first step in something larger. If this goes through unchallenged, then I foresee a whole new legal arms race to 'protect' ones citizens from, well, anything they like. Because this is '... but think of the children!' for a whole new era. This is classic government overreach. If you're living in New York, you need to get in touch with your local representatives and let them know, unequivocally, that this is a voting issue for you. That you will be watching to find out if they support this bill, and that if they do, you will be voting for the other guy. The best way to deal with this problem is not to 'get angry'. It's to 'get angry and get to work'. Forget waiting for the Lobbyists and their big money to tell you how it's going to be. If you want cryptos to survive - and this legislation, as stated, would make illegal having a QT wallet/node running on your computer - then -- every crypto-user on this planet -- is now a Lobbyist. And, for my fellow Shibes, if there's one thing that /Dogecoin has proven good at, it's in getting the word out there. We're smart, we're media savvy - we know how to get attention! So, let's get organized. Bring everyone on board - every coin, every crypto-user in every corner of the world. Let's get active. Because we've still got time to fight this. Together! It's 8:50AM EST and we've found 87.62% of our initial 100 Billion DOGEs -- only 12.38% remains until our period of Hyper-inflation ends! Our Global Hashrate is up from ~44 to ~46 Gigahashes per second and our Difficulty is up from ~641 to ~815. As always, I appreciate your support! GoodShibe EDIT: I've created this brainstorming thread to try and help get ideas moving. Come join me! EDIT 2: I've also started this post to ask for the community's permission/support to reach out to /bitcoin and other communities to try and organize a crypto-wide response to these regulations.
There is a 30 day comment period for the current Bitlicense proposal. Unless there are substantial changes, New York will be a Bitcoin dead zone
The 30 day comment period starts next week. Bitlicense, as proposed will force most companies that store customer BTC deposits to block New York IP addresses. There is very little chance that Lawsky will make any further changes to it, so what will this mean for Bitcoin around the world? EDIT, as a reminder: This is how the Bitlicense will affect Bitcoin businesses, taken from here: http://www.reddit.com/Bitcoin/comments/2aycxs/hi_this_is_ben_lawsky_at_nydfs_here_are_the/cizyqyz (I've added modifications in light of changes in the new proposal and information that I found was missing in the original write-up) Entities are considered dealing in virtual currencies if:
They transfer Bitcoins on behalf of one person. This includes Bitcoin tipping (changetip), mixers, Blockchain.info Send Shared, CoinJoin, Dark Wallet(200.2n1)
They hold or have control over Bitcoins for their users. This includes Mining pools, Coinbase, Circle, Greenaddress.it, all exchanges. (200.2n2)
They buy or sell Bitcoins as a business activity. This includes Local Bitcoins sellers, #bitcoin-otc. FinCEN statements includes selling physical coinage (including casascius coins) also regulated. (200.2n3)
They create a virtual currency, even if it is decentralized. This includes creating altcoins. In fact, Satoshi would have commited a crime creating Bitcoin without registration. (200.2n5)
They trade any virtual currency, even for another virtual currency. This includes alt coin exchanges. Mintpal, Cryptsy, BTER, etc(200.2n4)
.. to any resident in New York. Web services, even those incorporated overseas, must either comply or block access for NY users. (200.2n) Entities 'dealing in virtual currency' must:
Perform AML and collect identities, including verification of government issued Photo ID and proof of address, and retain these information for 10 7 years. (200.15a). Verification of identity required for any accountholder that initiates transaction with a value over $3,000.
Retain all transaction logs for 10 7 years, including real name & physical addresses of ALL parties of a transactionaccount holders- yes, including whoever you are sending to.(200.12a1)
Report all transactions over the USD value of $3000 $10,000, and file Suspicious Activity Reports. (200.15g4)
Maintain collateral in the form of USDhigh quality, highly liquid, investment-grade assets, including collateral for Bitcoin balances. The % as collateral is unspecified.
Retained earnings and profits of in invested in US dollars. They may not keep any profit in Bitcoin.(200.8b)
Forfeit Bitcoins that are inactive for over 5 years to the State of New York - (200.12c)
Not obfuscate any transactions - Bitcoin mixing would be illegal. (200.15f)
Must get prior written approvalfor any plan or proposal to introduce or offer a new product, service, or activity, orto make a material change to an existing product, service, or activityfrom the State of New York
Pay$5000 application feefor getting a Bitlicense
The (only?) good news: Merchants do not need a BitLicense to accept Bitcoin for a good or service. (200.3c2). > This post was created for general guidance, and does not constitute legal advice. You should not act upon the information contained in this publication without obtaining specific advice from a professional. No representation or warranty (expressed or implied) is given as to the accuracy or completeness of the information contained in this post. EDIT 2, targetpro suggested expressing any concerns you may have about the proposed regs to the NY Dept. of Finan. Services:
Tragic implications of the BitLicense with respect to Bitcoin 2.0 applications, smart contracts, smart property, Bitcoin law, digital voting and Ethereum?
Now granted, I am not a lawyer. I am a commercial pilot by trade and as such please forgive any misconceptions that I may have picked up as a layman in the Bitcoin universe, for my intellect is small but my aspirations are lofty. It has occurred to me, however, that this proposed BitLicense represents problems for the Bitcoin ecosystem so far and above what may be evident at the moment. Mostly because regulators are attempting to square a circle and apply existing banking-type regulations to a digital and software controlled payment network/protocol. And not only that, if there is one thing that being in this community has taught me, it is to never underestimate the brilliance of these young new innovators in creating radical new concepts for the future... many of which (to me at least) would seem to be on a direct collision course with these BitLicenses. If I am wrong, please tell me why. Here is what I see so far... 1.) Smart contracts. If I enter into a smart contract facilitated by a lawyer's office and said office (as a part of its legal services) holds said private key/contract for me or transfers it to a third party as part of a multi sig transaction (let's say a will, deed or trust), would this lawyer now be considered a bitcoin business and as such be required to maintain all of the same onerous requirements as large exchanges and so forth? And more troublesome would seem to be the reporting requirements of this transfer. If attorney-client privilege is paramount and necessary, would not digital contract transferrence reporting requirements under the BitLicense now expose lawyers and/or their clients dealings to the public? Indeed, a promising aspect of digital bitcoin contracts/colored coins/etc would undoubtedly be their anonymity. What other businesses would undoubtedly try to harness Bitcoin for their purposes and what other unintended consequences could this regulation bring about? 2.) Ethereum presents us with the possibility to invent an entire universe of new digital financial products and contracts. Would each of these contracts require the transferring parties to be BitLicense holders as well? Would not DAC (digital autonomous corporations) touted by the Ethereum team also be vastly hampered by the reporting and financial requirements of the BitLicense? After all, such corporations would aim to be autonomously handling Bitcoin transactions of a global nature. This would seem to greatly hamper the innovative capacity of Ethereum which aims to allow multitudes of trustless decentralized systems in place of entrenched banking establishments. 3.) Would innovators designing new types of cryptocurrencies on potential sidechains to the Bitcoin network also be required to have BitLicenses? If those cryptocurrencies are actually pegged Bitcoin transactions on a side chain, do they even represent a "new" cryptocurrency at all for the purposes of regulatory oversight? What about test nets? Are these considered true cryptocurrencies at all if they only serve the purpose of being a testbed? 4.) Digital Ecosystem: If a decentralized, autonomous taxi cab service of the future (let's just imagine such a service for a moment, shall we?) employs a wallet service provider such as Blockchain.info, would this not subject each and every rider to the same strict identity requirements as those transacting with Bitcoin exchanges? I realize it depends on how the individual company handles the taxi cab transaction, but I venture to guess that most companies would elect to have a third party do this for them, and as such would not the third party be required, as a licensee, to identify the fares? I use a taxi cab as an example because this would seem to be a use case for forthcoming google cars and what not. I am sure that if you use your imagination you can envision a future where almost all services interact digitally using Bitcoin... 5.) Voting: If a cryptographic election system is put into place, and used in the state of New York, would such a system be subject to the BitLicense requirements? And If I use a satoshi or other discrete transaction to cryptographically verify on the Blockchain that I have cast my vote at the booth, and you process it, are you, as the voting authority not then required to identify me and keep those records on file? I am grasping on this one, but it does not seem out of the realm of possibility. As a mere layman, I am very troubled by the onerous requirements of the proposal set forth by Ben Lawsky. If even I, with my hamster brain, can envision such a universe of potential problems erupting from these regulations what does that say about the current state of our regulators? Am I wrong on many of my assumptions? Am I misreading the BitLicense? It would seem that perhaps regulators should adopt a wait and see approach before diving into this fray. Even the "experts" themselves do not truly know the implications of many of these evolving technologies. How will they interact? What innovative constructs will they give rise to? If even one of these constructs evolves to be the next "killer app" for Bitcoin what unintended consequences to the state of New York could this bring in hampering a potential supernova of innovative capacity and economic activity? As a regulator, you need to be asking yourself, "What is the purpose of my regulation, and how best can I adapt it to suit and protect the public which I serve. How can I foster innovation and invention while still creating a legal, stable and sound baseline for infrastructure to grow?" If said regulation hampers and stifles innovation, particularly with a global peer to peer network such as Bitcoin, it would seem to be trivial to push such innovation elsewhere, at the expense of your own tax coffers and revenues. More digital business=more money for you, the regulator. More regulation=less digital business. But most troublesome of all is the notion that many other states or governments might look on the proposed BitLicense as a template for their own misguided approaches at regulating the nascent and undiscovered land that is digital currency. I personally would be scared to death of approaching this task with haste. You simply DO NOT KNOW what you are doing, because none of us truly know yet. As such, you owe it to the people of the state of New York to start with a bare minimum and ADD TO. We all know that in the government, it is much easier to add to, than take away. On a slightly humorous note, it would seem that you are trying to square a circle, when in fact you should be looking at this is as trying to "infinity an infinity". Edit: I have contacted the NYDFS directly [email protected] to make an attempt to publicly comment on their proposal but have yet to receive a reply on the proper correspondence address.
Bitcoin Community, As many of you know, Bitpay is sponsoring the NCAA (college level) Bitcoin Bowl which plays the 26th at 8pm EST. http://stpetersburgbowl.com/ A huge thanks to Tony and the Bitpay team for putting the Bitcoin name out there, over their own company, and all the work done to get hundred of merchants accepting around the stadium. I'm excited to watch, just to see some crusty football announcers forced to talk about bitcoin. The Tampa Bay Times put out an article, finishing with a helpful “How Bitcoin Works,” with such gems as, “Now the QR code, after being scanned, links the merchant and the buyer's bitcoin wallet. The buyer then enters the amount owed, a private access code and payment approval. (You'll still pay tax on certain things. You can still tip your waiter at a restaurant. It's actually not that different. Well, kind of!)” http://www.tampabay.com/news/business/retail/at-espn-bitcoin-bowl-push-is-on-for-football-8212-and-cryptocurrency/2211278 Few bitcoiners are... traditionally interested in American football. I thought I'd put together a quick guide so that any bitcoiner can watch the game and sound like they know what they are talking about. With no further ado, How Football Works for Bitcoiners, with some silly analogies. bitcoin – I'm sure you have some far better ones... :) Quarterback: touches ball every offensive play, hands off to a running back, or passes to a receiver or tight end. Bitcoin analogy: Gavin Andresen. If he isn't on his game, it isn't a guaranteed loss, but everyone else will need to pick up the slack. Touchdown: Get into the end zone - either end of the 100 yard (91.44 meters for international readers) field yields your team 6 points, with a short kick for an additional point to make it 7 points. Bitcoin analogy: Price bubble – we're going to the moon! Both seem great and unstoppable at the time, there is a lot of irrational celebration, and in both cases, the game is rarely over. Touchdown celebration: https://www.youtube.com/watch?v=5dmqGg6Ccvw Randy Moss goes to the moon Price bubble celebration: http://i.imgur.com/UPuMUx8.jpg Bitcoin price goes to the moon Interception: Quarterback throws a pass, but the defense catches it, you have an interception. Bitcoin analogy:http://arstechnica.com/tech-policy/2014/11/feds-will-auction-off-19-million-in-bitcoins-from-alleged-silk-road-kingpin/ First Down: When the offense advances 10 yards or more from the line of scrimmage within 4 plays, they get a first down, and a set of new 4 plays. Bitcoin analogy: Block confirmation – this is the lifeblood of a football team, and the bitcoin space. Wait, is bitcoin dead yet? Wait..... http://isbitcoindeadyet.com/ Goxxed: A familiar term to bitcoiners, I propose as new football term to describe a play like this: https://www.youtube.com/watch?v=d2EOees58eQ Defense: Tries to halt the offense from advancing down the field and stop a touchdown. Bitcoin analogy: NY DFS headed by Ben Lawsky. Much like the terribly ranked Jacksonville Jaguars defense, they can't slow this thing down for long. http://espn.go.com/nfl/team/_/name/jax/jacksonville-jaguars Anyone have any better analogies? Excited to see what 2015 brings for Bitcoin - Justin Blincoe, Coinapult
It's February 19th, 2018. I wake up, check my phone. Good, bitcoin is up another 5% overnight to around $18k per coin. The world is starting to come around to the notion of decentralized currency, but us early adopters know there's still more to come. A lot more. I've been accumulating coins since 2014 with each paycheck. Not to brag, but I've got quite the nest egg. Best of all, nobody knows it but me. No bankers. No stock brokers. Just me and the blockchain. I shower and get dressed. I take my dog for a walk. The sun is shining and all of the drones are headed to their lousy jobs. My phone beeps. Ha, Roger Ver just tweeted that Western Union is getting bought by Coinbase. Nice. After a short breakfast I head to the car dealership where I test drive the latest from Tesla. Think I'll wait a bit. After world markets started quoting the price of oil in bitcoin, I don't really sweat the ups and downs of gas prices. Think I'll stick with what I have. Besides, I don't want my neighbors to realize that the scruffy guy next door is one of the richest people in town. I drop by my office (literally MY office since I own the whole building). Bitcoin is up another 2% on the WU news..sweet! Most of my tenants pay their rent in bitcoin. Every month they each swing by with a Trezor. No need for a shady middle man or bank. Ah, forgot to mention that my office building is actually an old bank. They seem to be closing up left and right these days. After a little work (have to keep up appearances, right) I close up and head over to the bar. Things are a little slow so I fire up some satoshi dice on the ol' android phone. Too bad IOS fell off the map...such a shame that ApplePay took the whole thing down. Over in the corner of the bar some goobers play video poker. Good luck fellas have fun putting your cash in uncle sam's wallet. With not much going on around town I head home and watch Rise and Rise of Bitcoin Part 7 on Netflix. Man I love that movie. The part about Lawsky's trial is my favorite part. Afterwards I fire up the grill and cook up some prime steaks from the butcher, paid for in bitcoin of course. I love getting a 20% discount for paying in bitcoin. Just as the delicious smoke starts drifting away from the grill, the neighborhood suckers start coming home from their jobs. Bet you guys wish you hadn't bet on fiat. Edit: Wow a lot of people think I'm nuts. I'm not saying that every single thing I predicted will come true. Also contrary to the negative comments I'm not obsessed with the price of bitcoin. This is just a thought exercise. It was Dwight Eisenhower that said "plans are useless, but planning is indispensable" Edit2: Trolls are jumping on my 20% discount prediction. What you fail to understand is that when bitcoin starts to take off people are not going to want to hold fiat because the value will drop. So business owners will have an incentive to be paid in a strong currency and willing to accept less of it relative to fiat. After all why would someone accept something that rises in value on par with something that loses value? Econ 101
When NY regulator comes to /r/IAmA to field questions about Bitcoin regulation Reddit uncharacteristically treats him respectfully and asks well informed and insightful questions. LOL JK it's a fucking mess.
Today there was an IAmA by the Superintendent of Financial Services of NY on Bitcoin regulation. Politics + Bitcoin = Bravery Typhoon. Mr. Lawsky was smart enough to choose questions that weren't too hostile or circlejerky. But the replies to his answers are some of the bravest circlejerking I've seen since MayMay June. Let's take a look:
So if you mean what you say, please explain how HSBC is still in business... +121
Because they paid enough money to have enough time for everyone to forget about it and forge enough proof to end up with the least possible damage. +43
If there is one thing that makes my blood boil with smug Redditors it's ellipses. They are always inserted as some sort of QED, implying the parent is being dishonest, or implying the parent is stupid. I hate it. If there is one thing that you'll see reoccur often if you read the post, it's droves of Redditors saying "BUT WAT ABOUT THE BIG BANKS!?". As if perfect regulation of a larger industry is required before regulating something else.
Why is HSBC and other banking firms still allowed to operate in NY? +50
JUST KICK EM' OUT. There are like a million WAT ABOUT HSBC comments here.
Also, why does Bitcoin get the hammer when everything else just slides under the radar when it comes to money laundering (I'm looking at HSBC)? +126
Last one, I swear.
I just want to thank you for doing this AMA. We appreciate being involved. +98
I guess doing an IAmA is the only way for a Reddit user to feel like they are being "involved"? There are better outlets. Anyway, these THANKS FOR DOING THIS NO QUESTION XD posts are becoming the norm in IAmAs.
... but not seriously enough to prosecute a single bank executive.... = loss of legitimacy +35
D-D-D-DOUBLE SMUG ELLIPSES BONUS ROUND
Hi XXXXX, you've been sent 8.6550 milli-bitcoins ($5.00) from XXXXX via /changetip. Collect it. +13
Whoa, what just happened here? +10
BenLawsky just got $5 worth of Bitcoin. Instantly. No fees. With a Reddit comment. +24
When will this END? Has the "Whoa, what just happened here" thing just become a meme now, and they're poking fun at themselves? I can't tell.
That's simply because they can't admit to using the NSA to build a parallel case +42
Man, if some NSA /panichistory starts taking root I'm going to have a euphoria overdose Alright, so there are some brave people that hoped onto Ben's comment to ride the karma train. But there are lots of other brave people who didn't get their totally legit, unloaded, and unbiased questions answered. Let's take a look at those
Since the actual Money Laundry Laws can't be applied to Big Banks & Financial Institutions (HSBC, etc) because of fears that the entire banking system would be destabilized. +25
How can money laundering laws be real if our eyes don't real? Seriously, what the fuck is this? HSBC was prosecuted and fined. You can certainly say that it wasn't sufficient, but obviously the laws exist and are enforced against big banks.
In your opinion should more be done to punish banks that have laundered billions of dollars? Do you think a small fine compared to the money the banks made off laundering is enough? +12
Man, this is so loaded I might have to steal it for an ELI5 post.
Hello Mr. Lawsky, from the news I heard that HSBC was involved in 1,9 bn$ money laundering and no criminal charges have been filed. It seems to me, the issue there is several magnitudes bigger than with bitcoin at the moment? Don´t you think, your time would be spent wiser, to takkle this problem first. +9
Maybe I'll use this one instead
[Bitcoin is] going to replace fiat currency and do away with the need for central banks. Advancements in decentralized and distributed technologies will allow that most other government functions to be replaced as well. +7
There wasn't really a question attached to this. Just some good ole' Bitcoin is gonna topple gubmit circlejerking.
My question is, have you read any of the discussions in /bitcoin about the hearings you've been involved in and the talks you've given? +7
If your goal is to have him take the Bitcoin community seriously you better hope he never sets foot in /bitcoin
What are your intentions for regulations regarding video game currency, since it can be traded/bought/sold for fiat currencies as well? It is a digital currency the same as bitcoin. Will there be fines imposed on people selling or buying their World of Warcraft gold from other people without some kind of license? +5
Eve Money is going to replace the USD. Just wait.
What benefit does your third party regulation bring to me and the person I'm willing to trade with? Can you maybe clarify for me that your financial regulation actually benefit customers and that it exceeds the "hidden costs" caused by your bureau? +4
"Please justify regulation. TYIA."
Maybe a slightly extreme question but if I want to pay someone for the right to assign a number to an address in a virtual ledger what does it have to do with you? +3
NOT IN MY BACK YARD IMAGINARY WALLET
What gives the NYDFS the authority to regulate a jurisdiction-less distributed computer system? Have you received a mandate from the open developer community behind crypto currencies or the majority of their user bases. +4
Does this guy really think the government needs permission from Bitcoin developers to regulate Bitcoin?
I know government is slow on everything, but when do you think the government will finally be able to gather its senses and take bitcoin mainstream? Also, do you see any chances of US government not embracing bitcoin at all? +2
I guess when they are cool without ditching the USD for a deflationary and volatile currency. I mean, I know I would have been totally cool if my mortgage was based in bitcoin and over the past three years the amount I owed grew a thousand fold.
Would you say that most Americans care more about stopping money laundering or creating jobs?
Because they are mutually exclusive?
Considering that it has been well established that the US government itself has been responsible for funding both drug cartels and terrorist organizations and has laundered money to do so, can you please explain what the major concern is over a relatively small and unused cryptocurrency? +3
It's said his fedora grew 3 sizes this day A majority of the questions are like this. Pages and pages of them. Hundreds. The worst part of the IAmA was he didn't even answer the important questions
Suppose that you agree with all the New York regulations and don't think that they will hurt small businesses. Or, you think that the bitcoin industry would be better served by large corporations that have compliance programs and insurance and all the other things that big banks do. However, if the New York regulations pass, bitcoins will actually become more expensive to use than dollars will, because the number of regulations proposed for bitcoins is higher than the number of regulations currently required for many types of banking activities. Bitcoins are useful largely because they can allow anyone to transact with very low fees. Even if the 1MB transaction limit is resolved, it will be expensive for payment processors to accept bitcoins when they have to comply with hundreds of pages of regulations. It seems difficult to imagine that Bitpay could continue to operate with their current fee structure if they have to hire people to push the massive amount of paperwork demanded by Lawsky.
Hardware wallet launched
The greatest positive news this week was the launch of the TREZOR hardware wallet. The launch is significant because the wallet is the first device which is immune to the standard viruses that spread on cell phones and computers. Since the code on the TREZOR is far simpler than the code of an operating system like Linux, the wallet is far more secure. Linux has thousands of packages, and any one of them could contain a security vulnerability which allows access to a hacker. Nobody understands all the Linux packages, but it is possible for one person to understand the firmware in the TREZOR. The ability for one person to understand the entirety of the code for a hardware wallet makes it less likely that there was an oversight allowing remote code to execute on the wallet. These are the devices that will expand bitcoin usage to people who don't know how to secure their money properly. Being able to plug one of these into a terminal at a grocery store is the end goal. They are more secure than cash, because they are useless to a hacker who steals them. Once the device is stolen, the person simply transfers the funds out of it before the hacker figures out how to break the password on the device. Unfortunately, the TREZOR will not result in any immediate bitcoin uptake and will remain a curiosity because of its high price. They are charging $119, which is unattractive to most people. Knowledgable people are not going to spend so much on something they can do themselves, and lazy people are not going to spend so much to start using bitcoins because they don't have to pay anything to open a credit card. The TREZOR is only important as a proof of concept that will hopefully be supplanted by a company who manufactures these at a lower price.
Russia banned bitcoins again
While everyone was wondering why the price of bitcoins dropped so much last week, it turns out that Russia banned bitcoins again. I guess that these bans still have some impact on the price. What's interesting about this is that the news was not reported anywhere - not in the press, not in /bitcoin, not on bitcointalk.org, but yet the price still went down a lot. That shows a few things: first, it's confirmation that people who hang around /bitcoinmarkets are not moving the market, and second, it means that the things that people around here pay attention to are not relevant to price. I read a lot of posts discussing theories of price rises and falls. Some reasons given are that people get paychecks on certain days, they are saving for Christmas, it's August, which means it's the vacation month in Europe, and so on. These reasons are off the mark. Bitcoin is big enough that people who put in a few dollars from each paycheck are not going to be the cause of $50 rises and falls.
VC bubble is accelerating
While most people are paying attention to bitcoin prices, the venture capital bubble surrounding bitcoins is accelerating. The amount of investment in bitcoin companies last quarter was more than all of last year combined. This rate of investment is clearly unsustainable and most of the VCs are going to be burned. It seems like there is a classic supply and demand problem here. There is a huge supply of money, with people wanting to throw millions into in anything that comes their way. On the other hand, there aren't that many products available for investment that require money. Most of the VC money has gone to mining hardware and exchanges, two types of companies that need money to get started. The cost of manufacturing ASICs is enormous, and complying with regulations is expensive. But there are only so many exchanges that the market can support. Eventually, the VCs will need to look for other companies to buy in to, like colored coin implementations and legal contracts and altcoin development. The problem, however, is that software development is not expensive. You don't need huge fabrication plants to start programming a new application of bitcoin technology. And software is what is most needed, as the great challenge now is providing killer applications for users to adopt bitcoins. Innovative software applications don't need millions of dollars in VC money to get started, so software companies don't accept the money because they have no reason to give away 90% of their companies. That creates the bubble. The VCs are squaring off against each other in fields which are saturated with competitors. Not only that, but the money going into those fields will push those businesses ahead of the curve. The VC-backed exchanges and payment processors will open, but the software that makes bitcoins useful to people won't be there yet. Most of those companies, which (like Circle) are burning cash at unsustainable rates, will collapse until the software applications catch up to them, and the VCs will lose a lot of money. moral_agent should create a "VC bubble" chart. I wonder if it is inversely correlated to the usual bubble chart.
An unbelievable waste of money
As another example of this bubble, the domain BTC.com was sold for $1.1m last night. If anyone reading this note can justify such spending, please let me know. Domain names are important, of course, but there is no possible way that a company can make $2m more by having BTC.com than a more branded domain name. Note that I say that the opportunity cost of purchasing the domain is at least $2m, because the $1.1m could have been invested in some other aspect of the buyer's business. Of course, the company can make more than $2m total, but to justify this purchase it would have to make $2m more than if it had an alternate domain name. On the other hand, like all bubbles, the buyer might be talking up his plans for the site just to hold on to the name for a while longer, so that he can sell it right before the VC bubble pops, so that the next sucker can lose all his money.
Good afternoon! Yesterday was the darkest day in at least the recent history of bitcoin, perhaps ever. I'll get into why yesterday was more significant than Mt. Gox and China later, but the end point of this post is going to be that these proposed regulations are a breathtaking expansion of government power into areas of commerce that have never traditionally been regulated. If this passes, we may well find ourselves fighting against bitcoin acceptance.
Some basic truth about The Law
First, it's important to eliminate a common misunderstanding in /bitcoinmarkets. Some users are arguing that this law (lowercase letters) isn't that bad because while it covers a broad range of activity, it is only intended as a tool to fight money laundering (or some other goal, depending on the user). People need to understand that the long arm of The Law (capital letters) does not care what laws were actually intended to do. You either violate them, or you do not. A judge isn't going to allow a business to operate based on the argument that this law was intended for a different purpose. As you make your evaluation of the effects of this law, you need to consider every possible activity that could be illegal under it. You can't write off certain activities because they were unintentionally added to the law. The Law is not compassionate and does not allow people to get away with things because the creators were trying to prevent some other behavior. There are many examples of poorly-designed laws that have had devastating unintended consequences.
Now that we are clear that the intent of the law doesn't matter, I thought it would be worth sharing how a few examples of bitcoin-related activities in New York will work. This section includes three rows each. The first is the activity, the second is an example of what I would consider some reasonable regulations, and the third is the actions needed for compliance under this law. Since there are an absurd number of requirements for each case, I only listed one or two of the most ridiculous for each. Activity: Operating a tipping bot that sends $0.25 tips to residents of New York that holds balances Reasonable: Require the tips to be backed with 100% reserve in the tipped currency Lawsky: Collect personally identifiable information about all people ever tipped, retain it for 10 years, and submit paperwork to the department when tips qualifying as "suspicious activity" are sent Activity: Changing a variable in the bitcoin code and creating a new blockchain for testing a proposed feature Reasonable: No regulation Lawsky: Register with the NYDFS, payi thousands of dollars, wait 90 days, and undergo a background check with the FBI Activity: Operating the Elgius mining pool, which adds PPLNS payouts to its own blocks, so that users never have outstanding balances Reasonable: Allow people to take civil action if their payouts don't match what they are owed Lawsky: Register as a money transmission service, develop compliance programs, and conduct "intrusion prevention" tests against the nonexistent wallets Activity: Running a business like blockchain.info, which does not hold any balances whatsoever in dollars and pays all employees and vendors in bitcoins Reasonable: Require recordkeeping of profits and expenses similar to current laws Lawsky: This business model is expressly prohibited; no business is allowed to take profits in bitcoins Activity: Operating an altcoin exchange, which takes untraceable litecoins and exchanges them for untraceable nanotokens Reasonable: Prohibit fractional reserve banking and require that reserves be kept in the currencies they are backing Lawsky: Requires altcoin exchanges to back its reserves in dollars and to associate every altcoin address with a username. If there is a bubble, the business goes under because it is no longer able to back customers' deposits. Activity: Being a one-time arbitrator, where two parties trade something and use a multisignature transaction with you as the decider in the case something goes wrong Reasonable: At most, require background checks on the arbitrator to verify his integrity Lawsky: File paperwork with security plans, a list of anyone who might help you with collecting evidence to make the decision (even if you are never called upon to do so), and obtain background checks and fingerprints for all of them; pay thousands of dollars to register, wait 90 days to be approved, file suspicious activity report if the transaction is over $3k regardless of whether you are called upon to arbitrate or not Activity: Modify your mining pool's pay-per-share algorithm to prevent block withholding attacks, or introduce a new algorithm like PPLNS, without branching out into other business areas Reasonable: No paperwork necessary Lawsky: File new request with the Department and wait 90 days for the new model to be approved before rolling out the feature, while competitors in other states launch immediately
Businesses no logner possible to be served to New York residents
In addition to the regulation requirements, there are also some types of business models that simply cannot overcome the regulations at all. Here are some of those types of businesses:
Any sort of mixing service that allows businesses to conceal from their competitors which vendor they are obtaining inventory from
Altcoin exchanges, because all altcoins are highly volatile and these businesses are required to have reserves backing altcoins in US dollars. The risk of an altcoin bubble is too high and would destroy any profit potential if one happened
Blockchain.info, which does not hold any accounts in dollars
Arguably, the following business types could also not operate in New York because of cost concerns:
Mining pools, because the profit margin is too low to justify compliance with all the regulations (and also because there could end up being fewer altcoins)
Open source software developers on the bitcoin protocol or other protocols like Ethereum, which requires a license when no profit is being taken to fund them
The greatest problem with these regulations is simply that there is no clause for the amount of money the company has to control. While we plan to take all possible security measures, our pool's greatest security measure is that we automatically pay out balances that are too large, so that we will never owe more than $10k in customer funds. If there were to be a hack, then we would simply eat the cost of less than $10k from personal funds because it is a small amount. The reason this works is because it would cost more than $100k to provide the sort of professional infrastructure that Lawsky is requiring, so even if the site were hacked ten times, and even if we never fixed the security holes, we would still be ahead. That's why this legislation is irreparably flawed and cannot be salvaged. It makes sense for people holding a billion dollars to be subject to strict regulations. It is nonsensical to require people who hold $5k in customer funds to spend $200k/yr in compliance measures, given that taking 40 hacks are still preferable to such ridiculous regulations.
The likely outcome of these regulations is less protection
Now that we know the local effects on certain types of businesses, we should ask what the end result is going to be a year from now, should these regulations not be completely overhauled. I propose that the end outcome of these regulations is going to be less consumer protection and more crime. The only businesses able to operate in New York will be huge banks and hedge funds. While the banks charge excessive fees and rip customers off, they already are far more trustworthy than Mark Karpeles ever was. They already practice good security anyway because they understand (unlike Mt Gox) that customer service is important. The law isn't going to have much impact on them. Furthermore, these guys aren't even into the bitcoin business yet, so (at least at first), the only people the law effects are the small guys. Meanwhile, everyone else other than the banks is going to do exactly what we may be forced to do: milk the system by applying for licenses and waiting as long as possible, and then, on the day before compliance is required, ban New York residents from our service and avoid doing business with anyone in New York. However, it will be impossible for us, or anyone else, to eliminate every single New York resident from our system no matter how hard we try or how good our intentions are. Because there is no minimum funds limit, New York residents are going to find that they are excluded from the use of nearly every altcoin, mining pool, exchange, open source project, wallet service, auction site, escrow system, and so on. They key here is that by making the regulations too hard to comply with, every site is going to be equalized. If the cost of compliance were low, then honest businesses would have no problem complying. When the cost of compliance is high, there is no distinction between honest and scam businesses because New York residents will have to do business illegally. This leads to more scams and losses of money. Whereas now a New York resident who uses a service available in New York can sue the provider of a scam, they have no recourse in this proposed new world. After all, the New York resident was engaging in illegal activity by using a non-licensed business. This allows scammers to directly target people who live in New York because they have fewer legal protections than do people who live in other states. I'm very glad that I do not live in New York right now, and I actually feel sorry for what those who have been in bitcoins since the beginning and who live in New York are going to be unable to take part in the future.
About money laundering
One of the reasons we got into this mess is because the Federal government ignored consumer protection. While they were issuing regulations about money laundering, people like Mark Karpeles were able to take advantage of a complete lack of attention to consumer protection. The Federal government wasted millions of dollars in its cases against bitcoin_charlie, who is not accused of stealing any money or participating in any violent behavior, while ignoring real consumers who were being ripped off by exchanges operating as fractional reserves like Mt Gox and Vircurex. BenLawsky is now able to seize upon the Federal government's inaction and make himself look like a hero of consumer protection because New York will do what the Feds didn't do. Proponents of anti-money laundering regulations argue that terrorists have been significantly hindered by restrictions in moving money. Terrorism is a great excuse for many things. Consider the case of airport x-ray screening devices. Every time a person goes through one of those devices, he has a 1 in 30 million chance of developing cancer as a direct result of the x-ray exposure pushing that person over the cumulative radiation exposure threshold at which cancer would develop. The risk of dying in a terrorist attack on the plane before the machines were installed was also about 1 in 30 million. Therefore, we spent hundreds of millions of dollars on machines that kill as many people as the terrorists do. Not only that, but anyone would rather die in a terrorist attack than go through chemotherapy and years of pain in a long, excruciating death. People seem to accept that money laundering rules are necessary, and are pushing the bar of regulation lower and lower every day. How much would your risk of death really increase if money laundering regulations were loosened? If you have a 1 in 1 million greater chance of death but vastly more freedom in your finances, wouldn't you take that? In a perfect world where people didn't die, that would be an unacceptable compromise. In our world, however, people do die. It is ludicrous that people allow themselves to become obese and then live in fear of a terrorist attack.
The creation of a new kind of criminality?
There were some shameful comments from people like the Winklevoss twins yesterday about how they appreciate regulation of the industry. For those guys, it's all about getting rich, which isn't surprising given how their wealth is largely based on winning lawsuits rather than actually creating stuff. Few people seem to be reading the text of the document and understanding how this goes beyond bitcoins. This is a breathtaking expansion of government power that has never been seen before in the financial world. The regulations in this document expand the scope of financial oversight into industries far removed from anything that is covered by existing financial regulations, like open source development. For the first time, they dictate how businesses may pay out profits and promote inefficiency by requiring a bitcoin -> dollar -> bitcoin conversion, widening the pockets of Coinbase. They signal the creation of a huge bureaucracy that will require ever more taxpayer dollars to process millions of "suspicious activity reports," licenses, and minute software changes. But most importantly, they require recordkeeping and information gathering of unprecedented scope, and trust so many entities to gather these records that they will be leaked to everyone. People running small mining pools that pay out $0.30 per day will be retaining passport numbers. Some people are viewing this as the "government" collecting information on people, but the government already has all this information. What will happen is that these records will be so prevalent because so many people are mandated to collect them that every hacker in the world will have a copy. In what other area of business are so many people required to keep huge databases of passport photos, utility bills, and other documentation that enables all sorts of criminal activity? These records will exist for at least 10 years, be copied in mergers and acquisitions, and leaked to the media and to the criminals, who will pay record sums for them. The criminals and rogue insiders can use the data not only to perform identity theft, but to learn everything you ever bought, who your contacts are, where you live, how much you earn, what time of day you are away from your house, and what sites you use. They can phish for passwords at just the sites you use, arrange a theft when they recognize you are on vacation, threaten to phone your employer with false allegations of rape unless you pay up, use stolen wallets to frame you by purchasing child pornography with them, and contact repressive governments to have you arrested for associating with a known dissident. That brings me back to the opening sentence in these thoughts for today. If these regulations pass and spread to other jurisdictions, we may actually find ourselves opposing the uptake of bitcoins. If more states adopt these regulations and people start adopting, then the stage will be set for an increase in government power to track everything about everyone, and a corresponding increase in criminal activity. I said in the past that bans on bitcoins would not have an impact on the technology because people would go somewhere else, so they were not a change to the fundamentals. Few anticipated such a dramatic expansion of government power like we saw yesterday. Using the technology to procure unprecedented amounts of data would be a change to the fundamentals which even Nakamoto probably didn't intend.
I apologize to those who I said I would reply to today. I'll address their comments later.
Coinbase transactions do not account for low volume
Some people like to point to "off-chain" transactions as the cause for bitcoin's recent lower volume. While off-chain transactions could theoretically reduce on-chain volume, the commonly repeated causes of such transactions are inaccurate. Bitpay, for example, does not use off-chain transactions at all, because they claim that they support "transparency." Coinbase does use off-chain transactions, but only when bitcoins are sent within its own network. However, these off-chain transactions are offset by an interesting mechanism that actually increases transaction volume beyond what normally would be expected. To see how this works, log into a Coinbase account and generate a new "receive address." Then send money to the new address. Immediately after receipt, Coinbase moves the money from the receive address into one of its larger wallets. To pay for his 8% of the production server, a partner in the mining pool recently sent 0.54 bitcoins to a Coinbase account where we hold the pool's reserve. Immediately after the bitcoins were received, he said that they were "moved." I asked him how that was possible, seeing as how the balance was correct, and it turns out that Coinbase reshuffles its wallets periodically. If you had looked at the blockchain and tried to compute transaction volume, you would have thought that 1.08 bitcoins was actually spent, but half of that was actually a duplicate transaction. Even if Coinbase is handling payments between users off-chain, this doubling of inbound transactions is significantly offsetting the reduction in volume caused by its off-chain transactions.
Danger signs forming
There are some danger signs forming that place the mid-term price of bitcoin as bearish. Every day, I am shocked at how there hasn't been a crash (which I still think is coming). Here's why the big investors are holding back in generating a new bubble.
The transaction volume is unbelievably low. It doesn't make sense that bitcoins can be supported at this price for so long with such a low volume. Volume has stopped increasing at the same rate as it was in the past, and that can't be explained entirely by off-chain transactions or any other known reason. If the reason the volume is low is because people simply don't find bitcoins useful, there is no way to fix that issue and investors will wait for a sign that people are willing to adopt them.
The regulations in New York significantly increased uncertainty. Lots of people were eagerly awaiting the New York regulations in the hopes that they would bring clarity to companies operating in New York. Instead of bringing clarity, they started a fight that will be waged for years. In the best case, Lawsky relents and produces a minimal set of regulations. The most likely case is where they pass with some revisions, and someone sues the day they are released. Lawsuits then will prevent implementation of any regulations for a long time. It is pretty obvious that this fight needs to go on for years now, even though that is going to significantly delay bitcoin uptake. It is far more important to correct the regulations than it is to give banks clarity to expand their operations.
The development crisis in core protocol code continues to hold the technology back. There are many features that could be implemented to make bitcoins more attractive for merchants, payment processors, and small businesses, but the only things getting done now are minor fixes and small improvements. The bitcoin daemon is still difficult to build and deploy on many operating systems, for example, and there are features that are talked about as possibilities but which are far down the road. Investors look at the state of development and are hesitatnt to invest in something where nobody may work on it.
The 1MB transaction limit still has no feasible solution. There is a price ceiling that cannot be exceeded because the 1MB transaction limit will make it impossible to move money at a reasonable cost to the exchanges to conduct trades. The bitcoin protocol can no longer be hard-forked, as too many companies have custom implementations and would oppose a change, so any solution to this problem needs to come as a secondary layers (like the "new P2Pool" idea). But there is no progress in resolving this issue, and some people think that it will be resolved in a day once there is a crisis that requires a solution.
Note that these danger signs don't include things like the claim that bitcoins are too difficult to use, or that few merchants accept them. The problems holding them back are all people-based. There aren't any difficult technical issues here. Every day these problems aren't resolved, the outlook becomes more negative. If the transaction volume stays low for a long time even as more merchants accept bitcoin, there is more evidence that people aren't interested in using them (and I have said that the only way bitcoins fail is if people aren't interested in using them). If the regulations are not revised, the long court battle will encourage banks to adopt other technologies because their outlook is more certain. If developers don't get to work, then altcoins will continue to increase in features and pose a risk of overtaking. If the 1MB transaction limit is not resolved, then the likliehood of a fork increases by people impatient to come to a solution. Right now, it seems that the current state of bitcoins is an uneasy calm that is waiting for any spark to ignite a big fallout. The timing aligns very nicely with the upcoming point where the current price will cross the lower boundary, as the lower boundary continues to increase while the price does not. If I were a frequent trader, I would be watching that point very closely to sell, because if the exponential growth that has held for 5 years breaks, we start a new pattern where all bets are off. Watching this transaction volume makes it very difficult not to panic sell. I'm going to search moral_agent's back posts to find on what date the lower boundary will reach $630 and post that date tomorrow. Perhaps we have a new date to watch out for.
Yesterday, we reached what others might call a "beta" stage of mining pool testing, by successfully deploying it to the production server, so I'll be notifying the people who volunteered to test tomorrow or Thursday.
Hello, this is Will from Novauri. You almost certainly haven't heard of our company before. We are not planning on releasing it for use until 2015, and we haven't spent a dime on marketing. Still, our team feels strongly about the emerging BitLicense regulations in New York, and I wanted to share the letter we sent to the DFS with the community today. We already shared our views within days of the proposal being released here, but we've had much more time to craft a formal response. You'll find an abbreviated version below, and a full copy of our letter on our website here. I know this is a somewhat 'dry' topic, but it's important to the future of bitcoin in the US. Our thoughts on this topic are below. Thank you. About Novauri Novauri is a virtual currency startup based in Denver, Colorado and San Francisco, California. Novauri will allow bitcoin users to purchase and sell bitcoin using ACH debits and credits from their bank accounts. The service will be available initially to US consumers in early 2015. We are different from our competitors in that Novauri will not control the private keys to our customers’ bitcoin addresses. Not only will Novauri never have access to customers’ private keys, but our systems are designed so we will never see private keys in unencrypted form. We intentionally built this feature into our service as a risk protection measure for our customers. Novauri cannot suffer from the catastrophic failures and massive internal thefts we’ve witnessed at services that pool customer bitcoin and control their private keys because Novauri never has control of our customers’ funds, bitcoin or US Dollars. We feel strongly that this feature is both safer for our customers and cheaper for us as a service provider. Our design requires no expensive security layers around pooled wallets, no insurance for massive, pooled wallets that are vulnerable to insider theft, or regulatory responsibility as a fiduciary holding retail customer deposits like a bank. Innovation, bitcoin, and concerns about the proposed rules We believe bitcoin and its underlying blockchain technology is the most significant invention of the century. Bitcoin allows for unique digital information that can exist safely on the open Internet without the protection of a central authority. Bitcoin’s unique combination of cryptography and “hashcash”-based proof of work consensus with an integrated economic incentive to participate in the consensus that also creates an automated, and fully predictable monetary policy is something we’ve never dreamed of before 2009. The applications for this technology extend far beyond payment systems, and have the capability to uniquely identify anything digitally; a possibility that becomes exponentially more exciting when it intersects with other emerging technologies, such as the Internet of things, drone applications, or holograph-based UI and peer-to-peer communications. That being said, we believe the proposed BitLicense regulation falls short in three key areas:
Redundancy with existing regulation, and creates unfair playing field,
KYC provisions and ineffective cyber security provisions are dangerous for consumers, and
Failure to create a risk-based system that scales with the risk of the service.
1) Redundancy with existing regulation, and creates an unfair playing field Novauri believes that the BitLicense regulation is written in such a way that it will greatly stunt growth and drive innovation to other States or Countries entirely. The regulation contains provisions that exclude existing banks from the rules entirely. Novauri recommends removing the provisions that exempt banks entirely, and replacing the redundant and overreaching language in these areas with a simple statement: The rules and regulations applying to bitcoin at a Federal level (especially from FinCEN) shall apply to all applicable virtual currency businesses with activities in New York State. 2) KYC provisions and ineffective cyber security provisions are dangerous for consumers Perhaps the most dangerous aspects of the proposed regulations are the identity verification processes. We’ve already seen the disasters that the data retention provisions in the Bank Secrecy Act have caused in terms of the ongoing identity theft epidemic. Every week another bank is hacked, and more and more personal information goes up for sale on the darknet. We feel that these issues are an unintended consequence of the data retention requirements in the BSA, as well as the decision by certain companies to monetize “big data”. Novauri feels that these are misguided regulations and business decisions, and is vehemently opposed to corporations storing and selling personal information. The economic costs of identity theft greatly outweigh any advertising revenue made by these companies, and the cost to taxpayers in reimbursing billions and billions of dollars in stolen tax refunds each year, to say nothing of the stress these unintended consequences cause normal people when they discover their identities have been stolen. This issue will be far worse with bitcoin, which features a public ledger. As soon as personal information is leaked, it can be associated with the blockchain and the entire financial history of individuals will be viewable by anyone. As written, Novauri feels the proposed KYC provisions in the BitLicense proposal constitute a potential threat to our National security. Novauri recommends that the NYDFS delay the requirements around KYC until a more elegant solution evolves that doesn’t risk massive identity theft incidents or violations of personal privacy. We recommend full synchronization with existing regulation, and revision such that an individual’s right to privacy is balanced against the needs of law enforcement. This synchronization should also include checks and balances that are non-existent today. Regarding “cyber security”, Novauri believes that the regulations are ineffective, as technologies are continuously evolving. Novauri recommends that the NYDFS require businesses that act as fiduciaries for customer deposits and maintain control of private keys to hold deposit insurance for 100% of the value of all fiat and virtual currency deposits. If the business has faulty security, the insurance company can make that determination and increase their premiums. In the event that the business’s security is unsafe, the insurance companies will not issue insurance at all. This is a “future proof” way to ensure cyber security without politicizing the topic or risking that rules and regulations become ineffective and anachronistic with time, as they almost certainly will as written. 3) Failure to create a risk-based system that scales with the risk of the service The proposed regulation doesn’t differentiate between businesses that exchange fiat for bitcoin while taking control of deposits, those that exchange fiat for bitcoin and do not take control of deposits, or even businesses that exchange no currency at all and have no responsibility as a fiduciary. This will effectively kill all small businesses and startups in the State of New York, and if these rules are used as a model in other States, will drive the industry offshore entirely. Novauri recommends creating at least two types of businesses under the proposed BitLicense regulation:
Virtual Currency Retail or Investment Banking Provider
Virtual Currency Retail or Exchange Service Provider
Virtual Currency Retail or Investment Banking Providers would be regulated in a manner similar to banks, but Virtual Currency Retail or Exchange Service Providers would be subject to minimal regulation. Again, Novauri highly recommends using insurance as a way to “future proof” the areas of cyber security and KYC provisions. In closing, given the possibilities presented by this emerging technology, Novauri requests that the NYDFS consider revising the rules heavily, adopting a progressive and risk-based approach that uses insurance in lieu of prescriptive measures, removes duplicative rules and regulations, and gives the technology the room it needs to grow and evolve. Sincerely, Will Madden Founder & CEO Novauri, LLC For a full version of our comments on the BitLicense proposal, please visit our website here.
There's a cover story at Wired today about the Dark Wallet software that aims to completely anonymize transactions. Built on top of bitcoin, Dark Wallet merges transactions through a method known as CoinJoin, making it impossible to trace the destination of funds. The creators state that the goal of Dark Wallet is to make bitcoin transactions completely anonymous. I like Dark Wallet because it is built on top of the bitcoin protocol. Darkcoin, an alternative system that aims to accomplish the same thing, is more centralized (it has masternodes). Darkcoin also suffers from the simple fact that it is an altcoin, which is reason enough to believe that it is unlikely to succeed. Dark Wallet's success is more likely, because it theoretically could be used interchangably with the existing protocol. Since money flows over bitcoin and there are no colored coins representing larger values, a Dark Wallet coin is worth the same as a bitcoin. Should people start to use Dark Wallet, I predict that the Dark Wallet protocol becomes implemented by all major providers within a year of that. Should that happen, Dark Wallet will eventually become the default protocol, since traditional bitcoin has no advantages over Dark Wallet (who doesn't want to protect their privacy?) We could see it integrated into the reference client, just as the reference client uses new change addresses now to protect privacy. Ironically, the only use the non-Dark Wallet protocol would have then is for transparency purposes like proofs of reserve and huge bank transfers, so that straight bitcoin suddenly goes from the evil anonymous currency to the transparency enforcer. Pay attention to Dark Wallet. Because it is not an altcoin, and because it is so interchangable with straight bitcoin, it could eventually become the standard protocol should people start using it.
The difference between good news and actual products
I wonder if some of the discrepency between actual prices and the amount of good news that seemingly appears is because much of the good news is not actually what it seems. I was surprised to discover this morning, for example, that 1-800-flowers isn't actually accepting bitcoins. They only announced that they will be doing so later in the year, which adds them to a string of companies which stated they would be accepting bitcoins but turned out that only a small segment of the business was doing so, or that these companies' bitcoin acceptance wasn't live yet. It's also worth considering that many press releases have no real product behind them. Circle, which issued a release in mid-May, said that they were going to allow people to buy bitcoins with a credit card for no charge. Two months later, we have yet to hear a single person who has been accepted into their beta testing program. Therefore, I propose that one reason that good news has little effect on the markets is that it isn't actually good news. Perhaps the big time investors who actually make a difference see through the press releases more easily than the people on reddit do.
Why go bearish so early?
Some people questioned why I would have a negative outlook on bitcoins several weeks before we can confirm that this bubble cycle failed to launch. After all, the expected time that this bubble would peak isn't close to arriving yet. Over the past year, market movements have tended to occur about 10 days before the majority of people on reddit believed that they would happen. You can see this correlation in the crashes and rises last November pretty clearly. I've predicted that things aren't turning out the way many people believed, and that such an outcome would likely produce a downturn (but not kill bitcoins). Because things happen often happen before everyone believes they will, I would imagine that the fallout would occur before the expected timeframe of this bubble elapses.
On the New York regulations
Much has been made about how Benjamin Lawsky's proposed regulations will have a significant impact if they are released in a few weeks. I predict no impact at all. First, any regulations that are released are not going to be final; they still need to be discussed and approved. Therefore, companies will not be able to act upon them without fear of the rules changing before they are finalized months from now. Second, these regulations were to have been completed several weeks ago, and are still outstanding. As people in /bitcoinmarkets say, it's always coming "in two weeks." Finally, even if these regulations were finalized two weeks from now, there aren't any companies ready to pounce on them. Other regulations like money transmitting licenses, and simply not having the software ready, are greater hindrances at this point to these companies. Lawsky's regulations are important, but the timeframe in which they will have an effect is going to be drawn out well into the future. When they are finally approved, there probably wouldn't be much splash, since the splash always is made on the initial announcement. Their approval will set the stage for growth, but not until they are finalized and the companies are ready to go.
Litecoins are like bitcoins of the altcoin world
It occurred to me recently that people separate cryptocurrencies into two areas: bitcoins and everything else (altcoins). In some ways, altcoins can be separated into litecoins and everything else. In these contexts, bitcoins and litecoins share many characteristics. Both were the first, and most widely used, in their fields. Both use proven algorithms and provide a barebones framework, rather than attempting to experiment with extra features like anonymity or using 6 algorithms. Both serve as a reserve currency against which other cryptocurrencies are measured. Both have established uses that people need to hold them for to conduct real commerce. And both can be traded directly for dollars. This is why I do not believe that litecoins are going away. The idea of "silver and gold" is not a misdirection; the simple fact that litecoins are worth less than bitcoins has made them valuable in a number of instances where eight decimal places of bitcoins is not granular enough. Just as bitcoins' most important attribute is their network effect, litecoins have a smaller, but similar network effect. Convincing people to switch out litecoins for Darkcoins or whatever flavor of the day comes up next will be just as difficult as it would be to convince people to drop bitcoins in favor of some other currency.
Uses for the sockpuppet accounts
It's worth paying attention to flairs in /bitcoinmarkets for unusual activity. One thing those sockpuppet accounts could be used for is to influence the bulls-to-bears ratio. In yesterday's comment, I referred to the "weighted bulls to bears ratio," which is a better metric that minimizes the effects of such accounts.
Hopefully people will understand that I'm going to ask Kibubik to take a stronger hand against rule #1 ("be excellent to each other"). Most people are fine; my concern is the posts that are engaging in namecalling. I was called enough names in middle school to deal with it, but the problem is that when someone calls me names, it sets a precedent that it's OK to call other people names, and generally brings down the quality of discussion. I would ask that people word their responses so that they criticize the content of my or others' posts, and avoid unnecessary attacks that are not relevant to the current discussion. Since I do not delete posts in these comment threads, Kibubik will make the final call on what he considers inappropriate.
On Bitcoin regulations he would like to see put in place, Ben Lawsky said: “We’d like to see consumer protection. So when people entrust their money to a bitcoin wallet or a bitcoin exchange or another service, that we don’t have a situation like we had in Japan last year with Mt. Gox…We want to see sufficient cyber security to prevent terrible hacking, and we want to see enough ... On Bitcoin regulations he would like to see put in place, Ben Lawsky said: “We’d like to see consumer protection. So when people entrust their money to a bitcoin wallet or a bitcoin exchange or another service, that we don’t have a situation like we had in Japan last year with Mt. Gox…We want to see sufficient cyber security to prevent terrible hacking, and we want to see enough ... Benjamin Lawsky, the former New York state financial services chief, certainly wasn't a fan of bitcoin. But now, he's warming up to blockchain. Ben Lawsky. Developers, miners and individuals using bitcoin will generally not be regulated by the impending ‘BitLicense’ proposals, according to Benjamin Lawsky, superintendent of the New York Department Financial Services (NYDFS). Speaking at the Benjamin N Cardozo School of Law, New York, Lawsky clarified that many individuals and companies working within the bitcoin space will not ... Lawsky: Bitcoin Developers and Miners Exempt from BitLicense Bitcoin developers, ... For example, a software developer who creates and provides wallet software to customers for their own use will not need a license. Those who are innovating and developing the latest platforms for digital currencies will not need a license.” However, Lawsky stressed that companies involved in safeguarding ...
This video is unavailable. Watch Queue Queue. Watch Queue Queue Anyway, today I am showing you the easiest and fastest way I found to claim and sell your Bitcoin Cash. I am doing this by exporting my private keys to Electron Cash wallet, then selling them via ... Bitcoin activist Theo Chino confronts infamous New York regulator Benjamin Lawsky about his even more infamous BitLicense...and gets video of it! How to buy your own ad on - or donate to - the ... www.muchbitcoin.org = Learn more about Bitcoin This video is unavailable. Watch Queue Queue. Watch Queue Queue