Everyone knows that when you give your assets to someone else, they always keep them safe. If this is true for individuals, it is certainly true for businesses.
Custodians always tell the truth and manage funds properly. They won't have any interest in taking the assets as an exchange operator would. Auditors tell the truth and can't be misled. That's because organizations that are regulated are incapable of lying and don't make mistakes.
First, some background. Here is a summary of how custodians make us more secure:
Previously, we might give Alice our crypto assets to hold. There were risks:
- Alice might take the assets and disappear.
- Alice might spend the assets and pretend that she still has them (fractional model).
- Alice might store the assets insecurely and they'll get stolen.
- Alice might give the assets to someone else by mistake or by force.
- Alice might lose access to the assets.
But "no worries", Alice has a custodian named Bob. Bob is dressed in a nice suit. He knows some politicians. And he drives a Porsche. "So you have nothing to worry about!". And look at all the benefits we get:
- Alice can't take the assets and disappear (unless she asks Bob or never gives them to Bob).
- Alice can't spend the assets and pretend that she still has them. (Unless she didn't give them to Bob or asks him for them.)
- Alice can't store the assets insecurely so they get stolen. (After all - she doesn't have any control over the withdrawal process from any of Bob's systems, right?)
- Alice can't give the assets to someone else by mistake or by force. (Bob will stop her, right Bob?)
- Alice can't lose access to the funds. (She'll always be present, sane, and remember all secrets, right?)
See - all problems are solved! All we have to worry about now is:
- Bob might take the assets and disappear.
- Bob might spend the assets and pretend that he still has them (fractional model).
- Bob might store the assets insecurely and they'll get stolen.
- Bob might give the assets to someone else by mistake or by force.
- Bob might lose access to the assets.
It's pretty simple. Before we had to trust Alice. Now we only have to trust Alice, Bob, and all the ways in which they communicate. Just think of how much more secure we are!
"On top of that", Bob assures us, "we're using a special wallet structure". Bob shows Alice a diagram. "We've broken the balance up and store it in lots of smaller wallets. That way", he assures her, "a thief can't take it all at once". And he points to a historic case where a large sum was taken "because it was stored in a single wallet... how stupid".
"Very early on, we used to have all the crypto in one wallet", he said, "and then one Christmas a hacker came and took it all. We call him the Grinch. Now we individually wrap each crypto and stick it under a binary search tree. The Grinch has never been back since."
"As well", Bob continues, "even if someone were to get in, we've got insurance. It covers all thefts and even coercion, collusion, and misplaced keys - only subject to the policy terms and conditions." And with that, he pulls out a phone-book sized contract and slams it on the desk with a thud. "Yep", he continues, "we're paying top dollar for one of the best policies in the country!"
"Can I read it?' Alice asks. "Sure," Bob says, "just as soon as our legal team is done with it. They're almost through the first chapter." He pauses, then continues. "And can you believe that sales guy Mike? He has the same year Porsche as me. I mean, what are the odds?"
"Do you use multi-sig?", Alice asks. "Absolutely!" Bob replies. "All our engineers are fully trained in multi-sig. Whenever we want to set up a new wallet, we generate 2 separate keys in an air-gapped process and store them in this proprietary system here. Look, it even requires the biometric signature from one of our team members to initiate any withdrawal." He demonstrates by pressing his thumb into the display. "We use a third-party cloud validation API to match the thumbprint and authorize each withdrawal. The keys are also backed up daily to an off-site third-party."
"Wow that's really impressive," Alice says, "but what if we need access for a withdrawal outside of office hours?" "Well that's no issue", Bob says, "just send us an email, call, or text message and we always have someone on staff to help out. Just another part of our strong commitment to all our customers!"
"What about Proof of Reserve?", Alice asks. "Of course", Bob replies, "though rather than publish any blockchain addresses or signed transaction, for privacy we just do a SHA256 refactoring of the inverse hash modulus for each UTXO nonce and combine the smart contract coefficient consensus in our hyperledger lightning node. But it's really simple to use." He pushes a button and a large green checkmark appears on a screen. "See - the algorithm ran through and reserves are proven."
"Wow", Alice says, "you really know your stuff! And that is easy to use! What about fiat balances?" "Yeah, we have an auditor too", Bob replies, "Been using him for a long time so we have quite a strong relationship going! We have special books we give him every year and he's very efficient! Checks the fiat, crypto, and everything all at once!"
"We used to have a nice offline multi-sig setup we've been using without issue for the past 5 years, but I think we'll move all our funds over to your facility," Alice says. "Awesome", Bob replies, "Thanks so much! This is perfect timing too - my Porsche got a dent on it this morning. We have the paperwork right over here." "Great!", Alice replies.
And with that, Alice gets out her pen and Bob gets the contract. "Don't worry", he says, "you can take your crypto-assets back anytime you like - just subject to our cancellation policy. Our annual management fees are also super low and we don't adjust them often".
How many holes have to exist for your funds to get stolen? Just one.
Why are we taking a powerful offline multi-sig setup, widely used globally in hundreds of different/lacking regulatory environments with 0 breaches to date, and circumventing it by a demonstrably weak third party layer? And paying a great expense to do so?
If you go through the list of breaches in the past 2 years to highly credible organizations
, you go through the list of major corporate frauds (only the ones we know about)
, you go through the list of all the times platforms have lost funds
, you go through the list of times and ways that people have lost their crypto from identity theft, hot wallet exploits, extortion, etc... and then you go through this custodian with a fine-tooth comb and truly believe they have value to add far beyond what you could, sticking your funds in a wallet (or set of wallets) they control exclusively is the absolute worst possible way to take advantage of that security.
The best way to add security for crypto-assets is to make a stronger multi-sig. With one custodian, what you are doing is giving them your cryptocurrency and hoping they're honest, competent, and flawlessly secure. It's no different than storing it on a really secure exchange. Maybe the insurance will cover you. Didn't work for Bitpay in 2015. Didn't work for Yapizon in 2017. Insurance has never paid a claim in the entire history of cryptocurrency. But maybe you'll get lucky. Maybe your exact scenario will buck the trend and be what they're willing to cover. After the large deductible and hopefully without a long and expensive court battle.
And you want to advertise this increase in risk, the lapse of judgement, an accident waiting to happen, as though it's some kind of benefit to customers ("Free institutional-grade storage for your digital assets.")? And then some people are writing to the OSC that custodians should be mandatory for all funds on every exchange platform? That this somehow will make Canadians as a whole more secure or better protected compared with standard air-gapped multi-sig? On what planet?
Most of the problems in Canada stemmed from one thing - a lack of transparency. If Canadians had known what a joke Quadriga was - it wouldn't have grown to lose $400m from hard-working Canadians from coast to coast to coast. And Gerald Cotten would be in jail, not wherever he is now (at best, rotting peacefully). EZ-BTC and mister Dave Smilie would have been a tiny little scam to his friends, not a multi-million dollar fraud. Einstein would have got their act together or been shut down BEFORE losing millions and millions more in people's funds generously donated to criminals. MapleChange wouldn't have even been a thing. And maybe we'd know a little more about CoinTradeNewNote - like how much was lost in there. Almost all of the major losses with cryptocurrency exchanges involve deception with unbacked funds.
So it's great to see transparency reports from BitBuy and ShakePay where someone independently verified the backing. The only thing we don't have is:
- ANY CERTAINTY BALANCES WEREN'T EXCLUDED. Quadriga's largest account was $70m. 80% of funds are in 20% of accounts (Pareto principle). All it takes is excluding a few really large accounts - and nobody's the wiser. A fractional platform can easily pass any audit this way.
- ANY VISIBILITY WHATSOEVER INTO THE CUSTODIANS. BitBuy put out their report before moving all the funds to their custodian and ShakePay apparently can't even tell us who the custodian is. That's pretty important considering that basically all of the funds are now stored there.
- ANY IDEA ABOUT THE OTHER EXCHANGES. In order for this to be effective, it has to be the norm. It needs to be "unusual" not to know. If obscurity is the norm, then it's super easy for people like Gerald Cotten and Dave Smilie to blend right in.
It's not complicated to validate cryptocurrency assets. They need to exist, they need to be spendable, and they need to cover the total balances. There are plenty of credible people and firms across the country that have the capacity to reasonably perform this validation. Having more frequent checks by different, independent, parties who publish transparent reports is far more valuable than an annual check by a single "more credible/official" party who does the exact same basic checks and may or may not publish anything. Here's an example set of requirements that could be mandated:
- First report within 1 month of launching, another within 3 months, and further reports at minimum every 6 months thereafter.
- No auditor can be repeated within a 12 month period.
- All reports must be public, identifying the auditor and the full methodology used.
- All auditors must be independent of the firm being audited with no conflict of interest.
- Reports must include the percentage of each asset backed, and how it's backed.
- The auditor publishes a hash list, which lists a hash of each customer's information and balances that were included. Hash is one-way encryption so privacy is fully preserved. Every customer can use this to have 100% confidence they were included.
- If we want more extensive requirements on audits, these should scale upward based on the total assets at risk on the platform, and whether the platform has loaned their assets out.
There are ways to structure audits such that neither crypto assets nor customer information are ever put at risk, and both can still be properly validated and publicly verifiable. There are also ways to structure audits such that they are completely reasonable for small platforms and don't inhibit innovation in any way. By making the process as reasonable as possible, we can completely eliminate any reason/excuse that an honest platform would have for not being audited. That is arguable far more important than any incremental improvement we might get from mandating "the best of the best" accountants. Right now we have nothing mandated and tons of Canadians using offshore exchanges with no oversight whatsoever.
Transparency does not prove crypto assets are safe. CoinTradeNewNote, Flexcoin ($600k), and Canadian Bitcoins ($100k) are examples where crypto-assets were breached from platforms in Canada. All of them were online wallets and used no multi-sig as far as any records show. This is consistent with what we see globally - air-gapped multi-sig wallets have an impeccable record, while other schemes tend to suffer breach after breach. We don't actually know how much CoinTrader lost because there was no visibility. Rather than publishing details of what happened, the co-founder of CoinTrader silently moved on to found another platform - the "most trusted way to buy and sell crypto" - a site that has no information whatsoever (that I could find) on the storage practices and a FAQ advising that “[t]rading cryptocurrency is completely safe” and that having your own wallet is “entirely up to you! You can certainly keep cryptocurrency, or fiat, or both, on the app.” Doesn't sound like much was learned here, which is really sad to see.
It's not that complicated or unreasonable to set up a proper hardware wallet. Multi-sig can be learned in a single course. Something the equivalent complexity of a driver's license test could prevent all the cold storage exploits we've seen to date - even globally. Platform operators have a key advantage in detecting and preventing fraud - they know their customers far better than any custodian ever would. The best job that custodians can do is to find high integrity individuals and train them to form even better wallet signatories. Rather than mandating that all platforms expose themselves to arbitrary third party risks, regulations should center around ensuring that all signatories are background-checked, properly trained, and using proper procedures. We also need to make sure that signatories are empowered with rights and responsibilities to reject and report fraud. They need to know that they can safely challenge and delay a transaction - even if it turns out they made a mistake. We need to have an environment where mistakes are brought to the surface and dealt with. Not one where firms and people feel the need to hide what happened. In addition to a knowledge-based test, an auditor can privately interview each signatory to make sure they're not in coercive situations, and we should make sure they can freely and anonymously report any issues without threat of retaliation.
A proper multi-sig has each signature held by a separate person and is governed by policies and mutual decisions instead of a hierarchy. It includes at least one redundant signature. For best results, 3of4, 3of5, 3of6, 4of5, 4of6, 4of7, 5of6, or 5of7.
History has demonstrated over and over again the risk of hot wallets even to highly credible organizations. Nonetheless, many platforms have hot wallets for convenience. While such losses are generally compensated by platforms without issue (for example Poloniex, Bitstamp, Bitfinex, Gatecoin, Coincheck, Bithumb, Zaif, CoinBene, Binance, Bitrue, Bitpoint, Upbit, VinDAX, and now KuCoin), the public tends to focus more on cases that didn't end well. Regardless of what systems are employed, there is always some level of risk. For that reason, most members of the public would prefer to see third party insurance.
Rather than trying to convince third party profit-seekers to provide comprehensive insurance and then relying on an expensive and slow legal system to enforce against whatever legal loopholes they manage to find each and every time something goes wrong, insurance could be run through multiple exchange operators and regulators, with the shared interest of having a reputable industry, keeping costs down, and taking care of Canadians. For example, a 4 of 7 multi-sig insurance fund held between 5 independent exchange operators and 2 regulatory bodies. All Canadian exchanges could pay premiums at a set rate based on their needed coverage, with a higher price paid for hot wallet coverage (anything not an air-gapped multi-sig cold wallet). Such a model would be much cheaper to manage, offer better coverage, and be much more reliable to payout when needed. The kind of coverage you could have under this model is unheard of. You could even create something like the CDIC to protect Canadians who get their trading accounts hacked if they can sufficiently prove the loss is legitimate. In cases of fraud, gross negligence, or insolvency, the fund can be used to pay affected users directly (utilizing the last transparent balance report in the worst case), something which private insurance would never touch. While it's recommended to have official policies for coverage, a model where members vote would fully cover edge cases. (Could be similar to the Supreme Court where justices vote based on case law.)
Such a model could fully protect all Canadians across all platforms. You can have a fiat coverage governed by legal agreements, and crypto-asset coverage governed by both multi-sig and legal agreements. It could be practical, affordable, and inclusive.
Now, we are at a crossroads. We can happily give up our freedom, our innovation, and our money. We can pay hefty expenses to auditors, lawyers, and regulators year after year (and make no mistake - this cost will grow to many millions or even billions as the industry grows - and it will be borne by all Canadians on every platform because platforms are not going to eat up these costs at a loss). We can make it nearly impossible for any new platform to enter the marketplace, forcing Canadians to use the same stagnant platforms year after year. We can centralize and consolidate the entire industry into 2 or 3 big players and have everyone else fail (possibly to heavy losses of users of those platforms). And when a flawed security model doesn't work and gets breached, we can make it even more complicated with even more people in suits making big money doing the job that blockchain was supposed to do in the first place. We can build a system which is so intertwined and dependent on big government, traditional finance, and central bankers that it's future depends entirely on that of the fiat system, of fractional banking, and of government bail-outs. If we choose this path, as history has shown us over and over again, we can not go back, save for revolution. Our children and grandchildren will still be paying the consequences of what we decided today.
Or, we can find solutions that work. We can maintain an open and innovative environment while making the adjustments we need to make to fully protect Canadian investors and cryptocurrency users, giving easy and affordable access to cryptocurrency for all Canadians on the platform of their choice, and creating an environment in which entrepreneurs and problem solvers can bring those solutions forward easily. None of the above precludes innovation in any way, or adds any unreasonable cost - and these three policies would demonstrably eliminate or resolve all 109 historic cases as studied here
- that's every single case researched so far going back to 2011. It includes every loss that was studied so far not just in Canada but globally as well.
Unfortunately, finding answers is the least challenging part. Far more challenging is to get platform operators and regulators to agree on anything. My last post
got no response whatsoever, and while the OSC has told me they're happy for industry feedback, I believe my opinion alone is fairly meaningless. This takes the whole community working together to solve. So please let me know your thoughts. Please take the time to upvote and share this with people. Please - let's get this solved and not leave it up to other people to do.
Facts/background/sources (skip if you like):
- The inspiration for the paragraph about splitting wallets was an actual quote from a Canadian company providing custodial services in response to the OSC consultation paper: "We believe that it will be in the in best interests of investors to prohibit pooled crypto assets or ‘floats’. Most Platforms pool assets, citing reasons of practicality and expense. The recent hack of the world’s largest Platform – Binance – demonstrates the vulnerability of participants’ assets when such concessions are made. In this instance, the Platform’s entire hot wallet of Bitcoins, worth over $40 million, was stolen, facilitated in part by the pooling of client crypto assets." "the maintenance of participants (and Platform) crypto assets across multiple wallets distributes the related risk and responsibility of security - reducing the amount of insurance coverage required and making insurance coverage more readily obtainable". For the record, their reply also said nothing whatsoever about multi-sig or offline storage.
- In addition to the fact that the $40m hack represented only one "hot wallet" of Binance, and they actually had the vast majority of assets in other wallets (including mostly cold wallets), multiple real cases have clearly demonstrated that risk is still present with multiple wallets. Bitfinex, VinDAX, Bithumb, Altsbit, BitPoint, Cryptopia, and just recently KuCoin all had multiple wallets breached all at the same time, and may represent a significantly larger impact on customers than the Binance breach which was fully covered by Binance. To represent that simply having multiple separate wallets under the same security scheme is a comprehensive way to reduce risk is just not true.
- Private insurance has historically never covered a single loss in the cryptocurrency space (at least, not one that I was able to find), and there are notable cases where massive losses were not covered by insurance. Bitpay in 2015 and Yapizon in 2017 both had insurance policies that didn't pay out during the breach, even after a lengthly court process. The same insurance that ShakePay is presently using (and announced to much fanfare) was describe by their CEO himself as covering “physical theft of the media where the private keys are held,” which is something that has never historically happened. As was said with regard to the same policy in 2018 - “I don’t find it surprising that Lloyd’s is in this space,” said Johnson, adding that to his mind the challenge for everybody is figuring out how to structure these policies so that they are actually protective. “You can create an insurance policy that protects no one – you know there are so many caveats to the policy that it’s not super protective.”
- The most profitable policy for a private insurance company is one with the most expensive premiums that they never have to pay a claim on. They have no inherent incentive to take care of people who lost funds. It's "cheaper" to take the reputational hit and fight the claim in court. The more money at stake, the more the insurance provider is incentivized to avoid payout. They're not going to insure the assets unless they have reasonable certainty to make a profit by doing so, and they're not going to pay out a massive sum unless it's legally forced. Private insurance is always structured to be maximally profitable to the insurance provider.
- The circumvention of multi-sig was a key factor in the massive Bitfinex hack of over $60m of bitcoin, which today still sits being slowly used and is worth over $3b. While Bitfinex used a qualified custodian Bitgo, which was and still is active and one of the industry leaders of custodians, and they set up 2 of 3 multi-sig wallets, the entire system was routed through Bitfinex, such that Bitfinex customers could initiate the withdrawals in a "hot" fashion. This feature was also a hit with the hacker. The multi-sig was fully circumvented.
- Bitpay in 2015 was another example of a breach that stole 5,000 bitcoins. This happened not through the exploit of any system in Bitpay, but because the CEO of a company they worked with got their computer hacked and the hackers were able to request multiple bitcoin purchases, which Bitpay honoured because they came from the customer's computer legitimately. Impersonation is a very common tactic used by fraudsters, and methods get more extreme all the time.
- A notable case in Canada was the Canadian Bitcoins exploit. Funds were stored on a server in a Rogers Data Center, and the attendee was successfully convinced to reboot the server "in safe mode" with a simple phone call, thus bypassing the extensive security and enabling the theft.
- Over $200m has been stolen impersonating users of cryptocurrency platforms by one group alone. Here's a list of 10 social engineering attacks against corporate companies. Here's an even larger case. While verification methods are improving, so are methods of identity theft and social engineering. We now have sim swapping and deep fake videos to contend with. Hackers have massive database sets of personal information they can utilize. As the sums at stake increase, so to will the level of effort criminals are willing to undertake. Obscurity for an insecure system will only postpone an attack until the "jackpot" is large enough.
- The very nature of custodians circumvents multi-sig. This is because custodians are not just having to secure the assets against some sort of physical breach but against any form of social engineering, modification of orders, fraudulent withdrawal attempts, etc... If the security practices of signatories in a multi-sig arrangement are such that the breach risk of one signatory is 1 in 100, the requirement of 3 independent signatures makes the risk of theft 1 in 1,000,000. Since hackers tend to exploit the weakest link, a comparable custodian has to make the entry and exit points of their platform 10,000 times more secure than one of those signatories to provide equivalent protection. And if the signatories beef up their security by only 10x, the risk is now 1 in 1,000,000,000. The custodian has to be 1,000,000 times more secure. The larger and more complex a system is, the more potential vulnerabilities exist in it, and the fewer people can understand how the system works when performing upgrades. Even if a system is completely secure today, one has to also consider how that system might evolve over time or work with different members.
- By contrast, offline multi-signature solutions have an extremely solid record, and in the entire history of cryptocurrency exchange incidents which I've studied (listed here), there has only been one incident (796 exchange in 2015) involving an offline multi-signature wallet. It happened because the customer's bitcoin address was modified by hackers, and the amount that was stolen ($230k) was immediately covered by the exchange operators. Basically, the platform operators were tricked into sending a legitimate withdrawal request to the wrong address because hackers exploited their platform to change that address. Such an issue would not be prevented in any way by the use of a custodian, as that custodian has no oversight whatsoever to the exchange platform. It's practical for all exchange operators to test large withdrawal transactions as a general policy, regardless of what model is used, and general best practice is to diagnose and fix such an exploit as soon as it occurs.
- False promises on the backing of funds played a huge role in the downfall of Quadriga, and it's been exposed over and over again (MyCoin, PlusToken, Bitsane, Bitmarket, EZBTC, IDAX). Even today, customers have extremely limited certainty on whether their funds in exchanges are actually being backed or how they're being backed. While this issue is not unique to cryptocurrency exchanges, the complexity of the technology and the lack of any regulation or standards makes problems more widespread, and there is no "central bank" to come to the rescue as in the 2008 financial crisis or during the great depression when "9,000 banks failed".
- In addition to fraudulent operations, the industry is full of cases where operators have suffered breaches and not reported them. Most recently, Einstein was the largest case in Canada, where ongoing breaches and fraud were perpetrated against the platform for multiple years and nobody found out until the platform collapsed completely. While fraud and breaches suck to deal with, they suck even more when not dealt with. Lack of visibility played a role in the largest downfalls of Mt. Gox, Cryptsy, and Bitgrail. In some cases, platforms are alleged to have suffered a hack and keep operating without admitting it at all, such as CoinBene.
- It surprises some to learn that a cryptographic solution has already existed since 2013, and gained widespread support in 2014 after Mt. Gox. Proof of Reserves is a full cryptographic proof that allows any customer using an exchange to have complete certainty that their crypto-assets are fully backed by the platform in real-time. This is accomplished by proving that assets exist on the blockchain, are spendable, and fully cover customer deposits. It does not prove safety of assets or backing of fiat assets.
- If we didn't care about privacy at all, a platform could publish their wallet addresses, sign a partial transaction, and put the full list of customer information and balances out publicly. Customers can each check that they are on the list, that the balances are accurate, that the total adds up, and that it's backed and spendable on the blockchain. Platforms who exclude any customer take a risk because that customer can easily check and see they were excluded. So together with all customers checking, this forms a full proof of backing of all crypto assets.
- However, obviously customers care about their private information being published. Therefore, a hash of the information can be provided instead. Hash is one-way encryption. The hash allows the customer to validate inclusion (by hashing their own known information), while anyone looking at the list of hashes cannot determine the private information of any other user. All other parts of the scheme remain fully intact. A model like this is in use on the exchange CoinFloor in the UK.
- A Merkle tree can provide even greater privacy. Instead of a list of balances, the balances are arranged into a binary tree. A customer starts from their node, and works their way to the top of the tree. For example, they know they have 5 BTC, they plus 1 other customer hold 7 BTC, they plus 2-3 other customers hold 17 BTC, etc... until they reach the root where all the BTC are represented. Thus, there is no way to find the balances of other individual customers aside from one unidentified customer in this case.
- Proposals such as this had the backing of leaders in the community including Nic Carter, Greg Maxwell, and Zak Wilcox. Substantial and significant effort started back in 2013, with massive popularity in 2014. But what became of that effort? Very little. Exchange operators continue to refuse to give visibility. Despite the fact this information can often be obtained through trivial blockchain analysis, no Canadian platform has ever provided any wallet addresses publicly. As described by the CEO of Newton "For us to implement some kind of realtime Proof of Reserves solution, which I'm not opposed to, it would have to ... Preserve our users' privacy, as well as our own. Some kind of zero-knowledge proof". Kraken describes here in more detail why they haven't implemented such a scheme. According to professor Eli Ben-Sasson, when he spoke with exchanges, none were interested in implementing Proof of Reserves.
- And yet, Kraken's places their reasoning on a page called "Proof of Reserves". More recently, both BitBuy and ShakePay have released reports titled "Proof of Reserves and Security Audit". Both reports contain disclaimers against being audits. Both reports trust the customer list provided by the platform, leaving the open possibility that multiple large accounts could have been excluded from the process. Proof of Reserves is a blockchain validation where customers see the wallets on the blockchain. The report from Kraken is 5 years old, but they leave it described as though it was just done a few weeks ago. And look at what they expect customers to do for validation. When firms represent something being "Proof of Reserve" when it's not, this is like a farmer growing fruit with pesticides and selling it in a farmers market as organic produce - except that these are people's hard-earned life savings at risk here. Platforms are misrepresenting the level of visibility in place and deceiving the public by their misuse of this term. They haven't proven anything.
- Fraud isn't a problem that is unique to cryptocurrency. Fraud happens all the time. Enron, WorldCom, Nortel, Bear Stearns, Wells Fargo, Moser Baer, Wirecard, Bre-X, and Nicola are just some of the cases where frauds became large enough to become a big deal (and there are so many countless others). These all happened on 100% reversible assets despite regulations being in place. In many of these cases, the problems happened due to the over-complexity of the financial instruments. For example, Enron had "complex financial statements [which] were confusing to shareholders and analysts", creating "off-balance-sheet vehicles, complex financing structures, and deals so bewildering that few people could understand them". In cryptocurrency, we are often combining complex financial products with complex technologies and verification processes. We are naïve if we think problems like this won't happen. It is awkward and uncomfortable for many people to admit that they don't know how something works. If we want "money of the people" to work, the solutions have to be simple enough that "the people" can understand them, not so confusing that financial professionals and technology experts struggle to use or understand them.
- For those who question the extent to which an organization can fool their way into a security consultancy role, HB Gary should be a great example to look at. Prior to trying to out anonymous, HB Gary was being actively hired by multiple US government agencies and others in the private sector (with glowing testimonials). The published articles and hosted professional security conferences. One should also look at this list of data breaches from the past 2 years. Many of them are large corporations, government entities, and technology companies. These are the ones we know about. Undoubtedly, there are many more that we do not know about. If HB Gary hadn't been "outted" by anonymous, would we have known they were insecure? If the same breach had happened outside of the public spotlight, would it even have been reported? Or would HB Gary have just deleted the Twitter posts, brought their site back up, done a couple patches, and kept on operating as though nothing had happened?
- In the case of Quadriga, the facts are clear. Despite past experience with platforms such as MapleChange in Canada and others around the world, no guidance or even the most basic of a framework was put in place by regulators. By not clarifying any sort of legal framework, regulators enabled a situation where a platform could be run by former criminal Mike Dhanini/Omar Patryn, and where funds could be held fully unchecked by one person. At the same time, the lack of regulation deterred legitimate entities from running competing platforms and Quadriga was granted a money services business license for multiple years of operation, which gave the firm the appearance of legitimacy. Regulators did little to protect Canadians despite Quadriga failing to file taxes from 2016 onward. The entire administrative team had resigned and this was public knowledge. Many people had suspicions of what was going on, including Ryan Mueller, who forwarded complaints to the authorities. These were ignored, giving Gerald Cotten the opportunity to escape without justice.
- There are multiple issues with the SOC II model including the prohibitive cost (you have to find a third party accounting firm and the prices are not even listed publicly on any sites), the requirement of operating for a year (impossible for new platforms), and lack of any public visibility (SOC II are private reports that aren't shared outside the people in suits).
- Securities frameworks are expensive. Sarbanes-Oxley is estimated to cost $5.1 million USD/yr for the average Fortune 500 company in the United States. Since "Fortune 500" represents the top 500 companies, that means well over $2.55 billion USD (~$3.4 billion CAD) is going to people in suits. Isn't the problem of trust and verification the exact problem that the blockchain is supposed to solve?
- To use Quadriga as justification for why custodians or SOC II or other advanced schemes are needed for platforms is rather silly, when any framework or visibility at all, or even the most basic of storage policies, would have prevented the whole thing. It's just an embarrassment.
- We are now seeing regulators take strong action. CoinSquare in Canada with multi-million dollar fines. BitMex from the US, criminal charges and arrests. OkEx, with full disregard of withdrawals and no communication. Who's next?
- We have a unique window today where we can solve these problems, and not permanently destroy innovation with unreasonable expectations, but we need to act quickly. This is a unique historic time that will never come again.
I got this stuff from Steve Aitchison, he wrote this review and posted it on Uptrennd. Figured I should put it on here as well since I truly believe this is an incredible moonshot. I'm personally holding SHR myself and am very convinced it will do extremely well.
Give a read through it and you will immediatly see why. Enjoy guys. Introduction
Imagine for a second the following scenario. You are a 2 car family. One car is used every day going back and forth to work, for shopping, all the little jaunts you and your husband like to go on. Your grown children are at university and come home for the weekends so the other car sits in the driveway all week and doesn’t get used during the week. What a waste of a perfectly good car. You think to yourself we could put that car to good use and actually help to pay for university fees, by renting it out during the week. However, then you think “well it’s only a little Ford Fiesta who’s going to want to rent that.” Well, it turns out a lot of people want to rent it and for a good price: £34 ($40) per day, a possible $800 per month.
Peer to peer car sharing has grown massively over the last few years and people are making serious money by letting our vehicles on a daily basis, emulating the Airbnb model. In fact companies like Turo, Getaround and Drivy, which has just been acquired by Getaround for $300 Million, are bringing in serious investors like Toyota, Softbank Vision Fund, Menlo Ventures, and IAC to the tune of over $800 Million.
A key difference between rental companies and peer to peer is that they have vastly improved technology with app interfaces that make locating assets and resources, reserving and using them, and making payment convenient and seamless. This, combined with location-specific analytics, allows by-the-minute access to assets and resources (e.g. cars or bicycles) and enables customers to pick up and drop these assets where and when convenient.
Car sharing is just one example of an industry that is being disrupted. We have seen, experienced and read about the amazing growth of Airbnb which is now estimated to be valued at $38 Billion. Airbnb has been so successful that companies like booking.com
are trying to get in on the act by adopting a similar model when it comes to booking accommodation.
There is also the phenomenal rise of bicycle rentals which we see in cities all over the world, not quite the same as peer to peer sharing, but it’s another rental model that is ripe for being disrupted by the new sharing model.
With this business model in mind what other areas could it be used in: Transport:
Used for the rental of cars, trucks, scooters, trailers, and even heavy vehicles. Delivery Drivers:
Facilitate booking and payment for delivery drivers. Agriculture:
Garden sharing, seed swap, bee-hive relocation, etc. Finance:
Peer to peer lending Food
bank, social dining Travel
Tours, shared tour groups Real Estate
Airbnb, co-housing, co-living, Couchsurfing, shared office space, house swapping. Time:
Labour, co-working, freelancing Assets
Book swapping, clothes swapping, fractional ownership, freecycling, toy libraries. Transportation
Car sharing, ride-sharing, car-pooling, bicycle sharing, delivery company, couriers And so much more!
This newly emerging, but highly fragmented sharing industry, is currently worth over $100 billion. It is predicted to grow to at least $335 billion by 2025.
As you can see from a few examples above the sharing economy has a lot of room to grow but what it doesn’t have, yet, is a company who can facilitate ALL of the above use cases in one place. That is until now! ShareRing is disrupting the disruptors by bringing everything together in one place and making it easy for you and me to share anything and everything and making it as easy as opening an app on your phone. Business Case
The sharing market has exploded over the last several years. This is due, in part, to the digital age we live in, as we now have over 2.82 Billion people with smart phones around the world. It also due to how easy the business model of sharing lends itself to the digital world, and how with the simple installation of an app we can access a plethora of markets to rent almost anything from.
Due to this rise of digital platforms and the proliferation of smartphones, revenues coming from sharing economy platforms are only expected to increase. It is estimated to grow to a $335 billion industry in 2025, compared to its $14 billion value in 2014. (PwC UK).
The beauty of the sharing economy is that it is a win/win/win situation for the person who wants to rent something for a few days or weeks, the person who is renting out, and the company who facilitates the ease of the transactions between the renter and the person renting out. Typically the renter will save a lot of money whilst renting out someone else’s apartment, car, bicycle, clothes, dog sitting services etc and they can almost be assured of quality due to the social side of the business model with reviews from real people. The person who is renting out can make additional income and will want good reviews and therefore keep the standard of service higher. The company that is facilitating all of this can make a lot of money on transaction fees, as well as from advertising, and partnership deals, and obviously have an exit strategy for possible buyouts.
When it comes to looking at the business model, ShareRing fits in to the Commission Based Platform as described in Ritter and Schanz study where they looked at the core difference in difference business models of the sharing economy: Singular Transaction Models, Subscription-Based Models, Commission-Based Platforms and Unlimited Platforms.)
Commission Based Platforms are dominated by (at least) triadic relationships amongst providers, intermediaries and consumers with a utility-bound revenue stream. These business models enable their customers to switch between provider and consumer roles by creating and delivering the value proposition. Only a few employees work for the intermediary and the value creation and delivery is externalized. From a consumer perspective, consumers are empowered to collaborate with each other and to design the collaboration terms by negotiating the terms and conditions of the content, creation, distribution and consumption of the value proposition. Depending on the orientation of the value proposition, consumers purchase commodities (Tauschticket, ebay), access commodities in a defined timespan (booking.com, Airbnb) or buy services (uber, turo) from occasional and professional providers found via an intermediary. The intermediary mainly focuses on nurturing a community feeling and reducing exchange insecurity by incorporating rating systems, micro-assurances and standardizations of payment and delivery into the platform. The platform mainly takes commissions for successful matching and executing trade. (Journal of Cleaner Production Volume 213, 10 March 2019, Pages 320-331) The USP of the ShareRing Business Model
The USP that ShareRing has is that it brings all of the different forms of sharing together in one app through partnerships and onboarding of users.
No other company, to date, is bringing everything together in such a way. However there are other factors that make ShareRing unique, which we will look at. Token Economics
SHR is a utility token and will be used to pay for transactions on the network, such as 'new booking', 'add asset', etc. SHR is used by providers to pay for their access to the ShareLedger blockchain, including the addition of assets, renting out of assets, adding attributes, adding smart contracts, and other features.
SharePay (SHRP) is used by customers to pay for the rental of assets.
Masternodes will also be a main feature of the SHR token. When a transaction fee is incurred, it will be distributed in a way that allows for masternode holders who provide a service to the platform to receive a reward from each transaction. Transaction fees are charged to sharing providers in SHR. The distribution of transaction fees will be as follows: 50% - will be distributed amongst the active masternode holders who host an active node on the blockchain at that point in time (these holders provide a service to the platform). The distribution will be based on a calculation of the Total Amount Staked and the total continuous uptime of the node. 50% - will be provided to ShareRing Ltd (view ShareRing owned masternodes) for various purposes that contribute to working capital and platform growth. Leased Proof of Stake Consensus
ShareRing have chosen the Leased Proof-of-Stake protocol as the consensus algorithm for ShareLedger. This choice is based on the practicality and security benefits evident in the Waves platform. It is also much more cost effective than Proof-of-Work (POW), and will not suffer from the current issues Bitcoin and other POW cryptocurrencies are facing such as scalability and electricity consumption.
As explained above master nodes will be a main feature but there is the other feature of lightweight nodes. A user with a lightweight node will be able to stake their tokens to a full node of their choosing and participate in reaching consensus. They will also be free to cancel their leasing at any time as there are no contracts or freezing periods. The more tokens that have been staked in a full node, the higher the probability the node will have in producing the next block. Since the reward is given based on the total number of tokens staked in the full node, there will always be a trade-off between the size of the full node and the percentage of the reward. As an average user of the platform, you will not need to have technical knowledge on how to set up a node nor will you have to download the entire blockchain in order to stake your tokens. Only a user who sets up a full node will be required to do this, making it simpler than ever for users to earn a reward for supporting the platform.
The return expected for staking is expected to be around 6 - 8% although this has yet to be confirmed. Buybacks
ShareRing are currently implementing a series of buybacks which started in the beginning of November:
The buyback operation is done at a random time during the week.
If there is enough liquidity, SHR tokens will be bought through a single market order at the time of buyback. In case there is not enough liquidity, a limit buy order at last sell order price will be placed on the market, and will remain open until it gets filled.
The buyback program was implemented to test the API purchase process for when live transactions occur on ShareLedger
The Buyback Program is expected to:
The Token Flow
- Reduce the supply of ShareTokens available in both public and private markets
- Bring New capital and fund inflows into the Shareledger
- Substantially magnify value creation for the ShareToken holders
ShareRing will bring in hundreds of merchants to list their rental products, either exclusively or as part of an aggregator system e.g. When you look at the likes of trivago.com they will list the best hotel prices from multiple merchants who are listed on their website. Essentially ShareRing will become part of the aggregator ecosystem and be listed on sites like trivago.com
as well as have exclusive agreements with merchants who are listed directly on their app.
ShareRing’s USP is that they have everything on one place as well as their OneID module with means buyers can get a hotel, rent a car, rent their ski equipment, book events all through the one app and using the OneID.
With that in mind they are going to attract a lot of merchants. This is where it gets exciting so pay attention to this part.
When a merchant is part of the ShareRing ecosystem and a buyer rents something from that merchant ShareRing will take a small % commission from that transaction. So say someone books a hotel for $100 for the night, ShareRing might take $0.50 as a commission. What ShareRing will then do is go to one of the exchanges that ShareRing (SHR) is listed on and buy SHR tokens directly using an API system using USDT.
Now, the actual commission has not been disclosed yet however if we assume even a 0.25% commission that means for every $100 Million worth of bookings made through the app will net ShareRing $250,000 which means buy backs of $250,000 for the SHR token, which increases the liquidity of SHR on the exchanges.
If you think $100 Million of bookings is a lot, booking.com
customers book around 1.5 Million rooms per day, if we estimate an average of $50 per room that is $75 million of bookings PER DAY or $2 Billion worth of bookings per month.
This revenue coupled with revenue from OneID and eVOA makes ShareRing profitable almost from day one of the app going live. OneID And eVOA
Another exciting development from the ShareRing team is the collaboration between ShareRings Self Sovereign Identity protocol and third party providers to bring OneID and eVOA which will utilise OneID
With the huge rise in E-commerce and with over 2.82 billion people who now own a smartphone we are entrusting our personal information to more and more centralised entities. These entities are frequently hacked and our information is leaked to outside parties.
ShareRing aims to tackle this with their service OneID module.
ShareRing’s OneID solution protects users' data by handling Know Your Customer (KYC) information through third parties and ShareRing’s Self Sovereign Identity Protocol. ShareRing does not hold any identifying information anywhere on its servers. It provides the ultimate security for the renter and also the provider, as the Protocol encrypts and stores your data in a secure manner within your device. Essentially, this means that it is near impossible for a hack or data leak to happen, simply because there is no centralized server of data for hackers to exploit.
The OneID module is very easy to use. The end-user needs to complete their ID submission only once, with the entire submission process requiring less than two minutes to complete. Once this step has been completed, the customers KYC is destroyed by the 3rd party document verification system and the OneID module allows merchants to verify a customer’s identity via a hashed verification packet, stored on the users device and ShareLedger. This removes the need for merchants to store or see personal information; safeguarding both merchants and users from fraud.
To create your ShareRing OneID, simply:
- Take a picture of your government ID document
- Take a selfie
- Confirm and submit your details
This is something I am really excited about for ShareRing and they already have made partnerships for other companies to use this feature which is another income stream for ShareRing. eVOA
E-Visa On Arrival allows applicants to apply online and receive a travel authorisation before departure – this eVOA can be shown at dedicated Thailand immigration counters on arrival at major Thailand airports, allowing travellers to pass through in minutes.
OneID system is scheduled to become the lynchpin technology in Thailand’s electronic Visa On Arrival (eVOA) system; one of only two companies to partner with Thai authorities to provide this service. The new Visa system eliminates much of the hassle involved in entering the country:
This is a strong validation of the OneID system - immigration controls are some of the most scrutinized processes in any branch of government, and if the OneID solution can operate to their standards then it is truly business-ready. As explained by our COO, Rohan Le Page:
“We are providing our OneID product for Thailand e-VOA (Visa On Arrival) that allows 5 Million travellers from 20 countries including China and India to complete the visa process on their mobile through our app. This provides a streamlined immigration process that negates the need for an expensive and time-consuming process when you get off the plane. Additionally, fraud is mitigated with several extra layers of security in the back end including our blockchain (ShareLedger) consensus model that makes all data immutable and all but impossible to hack.” Profit Margins on OneID
So how does ShareRing make money from OneID and eVOA?
With each application for an eVOA using the OneID module ShareRing will make an undisclosed commission. The e-VOA is available to citizens of 21 different countries and is intended for those who will be holidaying in Thailand and not working in the country.
This means that each eVOA will last for a period of around 15 days which effectively means that ShareRing will get commission multiple times from each person travelling to one of the 21 countries listed below:
Andorra, Bhutan, Bulgaria, China, Ethiopia, Fiji, India, Kazakhstan, Latvia, Lithuania, Maldives, Malta, Mauritius, Papua New Guinea, Republic of Cyprus Romania, San Marino, Saudi Arabia, Taiwan, Ukraine, Uzbekistan
The profits on this alone, according to projections, are worth millions of dollars per year to ShareRing, with a healthy growth of about 35% in raw profit over the next 5 years, ultimately netting the company about $1.5 million profit per quarter. The ShareLedger Blockchain Platform
ShareRing will utilize the registered intellectual property from the existing KeazACCESS framework (KEAZ: A car sharing company founded by Tim Bos) as well as improving it the blockchain experience in their team.
It will consist of fo the primary elements: SharePay (SHRP)
– SharePay is the base currency that will allow users of the ShareRing platform to pay for the use of third party assets. ShareToken (SHR) ShareToken (SHR)
is the digital utility token that drives sharing transactions to be written to the ShareRing ledger that is managed by the ShareRing platform. Account
– This will be a standard account, which such an account being represented by a 24-byte address. The account will contain 4 general fields: SHRP
– SharePay token balance SHR
– ShareToken balance ASSETS
– linked/owned by the account (see below for definition of an Asset) ATTRIBUTES
– Any additional attributes that are associated with this account. These attributes may be updated or added by Sharing Economy providers that utilise the ledger such as ID checks by rental companies. These attributes may be ‘global’ (i.e. used by any sharing providers) or ‘local’ (i.e. used by a specific sharing provider). Assets
– An asset represents a tangible real-world or digital asset that is being shared, such as a car, a house, industrial machinery, an e-book, and so on. Smart Contracts
– Similar to a number of other blockchain platforms, such as Ethereum and NEO, the ShareLedger blockchain will feature highly customisable smart contracts. These Smart Contracts will allow for decentralised autonomous applications that can be attached to an asset and/or account. Every smart contract will be Turing complete, meaning it will have the ability to implement sophisticated logic to manage the sharing of the assets. The smart contracts will be tested and reviewed by ShareRing in a sandbox as well as audited by reputable third-party code auditors prior to implementation. Proof of Stake Consensus
ShareRing have chosen the Leased Proof-of-Stake protocol as the consensus algorithm for ShareLedger. This choice is based on the practicality and security benefits evident in the Waves platform. It is also much more cost effective than Proof-of-Work (POW), and will not suffer from the current issues Bitcoin and other POW cryptocurrencies are facing such as scalability and electricity consumption. The ShareRing App
At the heart of the ShareRing project lies the ShareRing app:
A universal ‘ShareRing’ app is being developed that will allow anyone to easily see and use any sharing services around them. Each partner will have the option of developing a ‘mini’ app within the ShareRing app that will have functionalities specific to that partner. The app will use geolocation-based services to display the ShareRing services that are nearby Social Media Presence
Coming from a social media background I feel this is an extremely important area to look into, especially in the crypto world.
ShareRing has done an okay job in growing their social media presence however I feel it could be much better. Here is a look at some of the key stats for their online social media presence: Youtube:
191 Subscribers Instagram:
238 Followers Linkedin:
376 Followers Telegram:
6,525 members (very active) Twitter:
2,216 Followers (Fairly regular updates) Facebook:
Whilst social media may not be a priority just now I feel there has to be a big presence with image-based platforms and video-based platforms. Youtube and Instagram should be made a priority here as it spans all generations: Other News on ShareRing
There is a lot of stuff going on at the moment with ShareRing which is what makes it an exciting prospect. Rather than give information on each of them here are some highlights provided by the ShareRing team.:
- ShareRing's revolutionary ID management based module OneID.
- Worlds first Blockchain based eVOA in place with major Thai company targeting 5 to 10 million travellers from 20 countries.
- 2.6 million International Hotels/ Accommodation coming on to the Platform. Lots more to come!
- Partnership with HomeAway
- 200,000 Activites, Tours and Events added to the ShareRing App
- Multi Global Car Sharing Partnerships
- 1 Partner Directly Integrating SHR's OneID consisting of 1.2 million Vehicles across 150 Countries
- Luxury Car Brand Sharing Platform purely based on SHR
- SHR payment system SHRP available in 10% Taxi Terminals in Australia
- SHRP available in 10,000 EFTPOS Terminals Australia wide
- White Labelling Services incorporating ShareRings revolutionary OneID
- 20 Significant Unannounced Partnerships, more to come!
- Major Partners include -
- BYD (Largest Electric Car Maker in the World)
- DJI (Largest Drone Maker in the World)
- Keaz (300 locations around the world)
- Yogoo EV Car Sharing
- MOBI Alliance Member Overview of Positives and Negatives Negatives
Social Media and marketing possibly needs to be ramped up in order to bring more awareness to the project.
The roadmap and white paper has not been updated recently for 2019/2020 but this I believe is coming soon. Positives
With a low market cap project like ShareRing t
he risk to reward ratio is very good for retail and institutional investors.
Technical analysis of current prices, currently at 31 Satoshi, is also very good with resistance levels at 50, 77 and 114 Satoshi which would be nearing its all time high.
Referral program will increase the numbers of users that are currently using the site.
If ShareRing can capture even a small % of the overall sharing market then success looks assured.
There are 20 new announcements coming up and with Tim Bos looking for more partnerships it seems likely that ShareRing will break ATH prices soon.
Great long term hold, in my opinion. Realistic Expectations of ROI Short term (4 weeks - 12 weeks)
Short term looks great for ShareRing both from a TA point of view and a fundamental point of view.
With lots of news still to come out about ShareRing there is not going to be a shortage of fundamentals to drive the price up. From a TA point of view the next line of resistance stands at around the 50 Satoshi level which would complete a massive cup and handle formation from August 24th of this year. After that we are looking at resistances of 77 and 114 to reach near the all time highs which i expect ShareRing to reach going into 2020. Long term (6 Months - 2 Years)
If ShareRing can onboard users and keep on making partnerships at the same rate there will be no stopping it. It’s all about onboarding the users and utilising the most powerful marketing tool ever - word of mouth!
When a great app is realised with great and useful functionality then it tends to go viral and I am hoping this happens for ShareRing.
With a market cap at the moment of just under $6 Million then I don’t think it’s crazy to talk about 1000% increases in the next 2 years and I really believe that is being extremely conservative, given where we think crypto is heading as a whole.
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