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Enforcement Trends in Cryptocurrency
Latham & Watkins Financial Institutions Group & White Collar December 9, 2015 | Number 1904 Defense & Investigations Practice Enforcement Trends in Cryptocurrency Cryptocurrency is on the rise...and so are enforcement actions. In less than a decade, cyptocurrencies have grown from a novelty reserved for those dealing in the illicit into a robust platform embraced by financial institutions and businesses alike. Wall Street and strategic investors have increasingly taken note, working to adapt their technology, streamline market trading and integrate cryptocurrency into everyday financial transactions. The rapid adoption of cryptocurrencies has also led to increased government enforcement activity. These actions evidence US regulators’ appetite to investigate fraud and other violations linked to cryptocurrency — often using traditional laws and regulations. Given this increased government scrutiny, financial institutions and traders should understand how regulators have policed the virtual world in the past in order to be prepared for the future. Government Enforcement Actions in the Cryptocurrency Space Unsurprisingly, government regulators, including the Securities and Exchange Commission (SEC), the Department of Justice (DOJ), the Commodities Futures Trading Commission (CFTC), the Federal Trade Commission (FTC) and the Financial Crimes Enforcement Network (FinCEN), have become increasingly active in policing the cryptocurrency space. The below enforcement actions provide a bird’s-eye view of how the enforcement framework for cryptocurrencies -
Cryptocurrencies Exploring the Application of Bitcoin As a New Payment Instrument
Cryptocurrencies Exploring the Application of Bitcoin as a New Payment Instrument By Shinnecock Partners in association with Sophia Bak, Jimmy Yang, Peter Shea, and Neil Liu About the Authors Shinnecock Partners undertook this study of cryptocurrencies with the authors to understand this revolutionary payment system and related technology, explore its disruptive potential, and assess the merits of investing in it. Shinnecock Partners is a 25 year old investment boutique with an especial focus on niche investments offering higher returns with less risk than more traditional investments in long equities and bonds. Sophia Bak is an analyst intern at Shinnecock Partners. She is an MBA candidate at UCLA Anderson School of Management with a focus on Finance. Prior to Anderson, she spent five years at Mirae Asset Global Investments, working in equity research, global business strategy, and investment development. She holds a B.S. in Business Administration from Carnegie Mellon University with concentration in Computing and Information Technology. Jimmy Yang is a third-year undergraduate student at UCLA studying Business Economics and Accounting. Peter Shea is a third-year undergraduate student at UCLA studying Mathematics, Economics and Statistics. Neil Liu is a third-year undergraduate student at UCLA studying Applied Mathematics and Business Economics. Acknowledgements We are grateful to the individuals who shared their time and expertise with us. We want to thank John Villasenor, UCLA professor of Electrical Engineering and Public Policy, Brett Stapper and Brian Lowrance from Falcon Global Capital, and Tiffany Wan and Max Hoblitzell from Deloitte Consulting LLP. We also want to recognize Tracy Williams and Steven Kroll for their thoughtful feedback and support. -
State of Diversity and Inclusion in Blockchain December 23, 2019
State of Diversity and Inclusion in Blockchain December 23, 2019 AUTHOR Susan Joseph, Principal, Susan Joseph LLC Executive Director, Diversity in Blockchain REPORT FOUNDING SPONSORS The State of Diversity and Inclusion in Blockchain Diversity in Blockchain, Inc. Diversity in Blockchain (“DIB”) is a not-for-profit organization with 501(c)(3) status that is committed to creating equal, open, and inclusive opportunities in the blockchain industry. Our co- founders include Susan Joseph, Anna Ashurov, Michelle Gitlitz, Shawnna Hoffman and Joshua Ashley Klayman. DiB’s mission is to empower everyone from all walks of life to engage with blockchain technology to ensure equal participation and distribution. True innovation includes everyone. This report was written by Susan Joseph, Executive Director of Diversity in Blockchain, Inc. and Principal of Susan Joseph LLC1 for Diversity in Blockchain’s use and to aid the Blockchain Industry. If you can measure things, you can change them. We hope that this report creates a benchmark with regard to Diversity and Inclusion in Blockchain and supports a Call to Action and Task Force to develop Best Practices for this sector. Susan Joseph Biography Susan is a JD/MBA, former General Counsel and Principal at SusanJosephLLC, a consulting firm, and owner of the Law Firm of Susan Joseph. She advises and consults on law, blockchain, and fintech, including cryptocurrencies, enterprise digital ledgers, digital assets and wallets, insurance/insurtech, smart contracts, consortia, regulatory issues, policies and compliance, decentralized identity and privacy, open source strategies, and other issues as they occur across financial services, real estate, supply chain, and insurance. She currently is the Civics Representative for RiskStream and was formerly the B3i North America Representative (Insurance Consortia). -
Virtual Currency
Office of Legislative Research Research Report December 12, 2014 2014-R-0290 BITCOINS - VIRTUAL CURRENCY By: Michelle Kirby, Associate Analyst ISSUE BITCOINS The use of bitcoins as virtual currency, the laws that Bitcoin is a form of virtual or digital currency. It is govern it, and other states’ attempts to regulate it. not legal tender and is not backed by any This report updates OLR Report 2014-R-0050. government. Federal agencies such as SUMMARY the U.S. Treasury “Bitcoin” is a form of virtual or digital currency, that Department, the Government Accountability allows financial transactions to be conducted on a Office, the Internal network using computer codes. It is a form of Revenue Service, and the exchange that operates like a currency but does not Congressional Research Services have issued have all the attributes of real currency. guidance on how existing laws apply to virtual There are no federal or state laws that specifically currency activities. govern bitcoins. However, many existing laws apply to A proposed federal law certain virtual currency activities. calls for a five-year moratorium on bitcoin The U.S. Treasury Department’s Financial Crimes regulation. Enforcement Network (FinCEN) has provided guidance New York has proposed indicating that, under federal law, a virtual currency regulation that would, user is not a money transmitter and is therefore not among other things, subject to the registration, reporting, and require firms engaged in virtual currency to have a recordkeeping regulations for money services BitLicense. businesses (MSBs). However, virtual currency California has enacted a administrators and exchangers may be regulated as law that allows the use of money transmitters but should not be considered alternative currency. -
Social Network
DEADLINE.com FROM THE BLACK WE HEAR-- MARK (V.O.) Did you know there are more people with genius IQ’s living in China than there are people of any kind living in the United States? ERICA (V.O.) That can’t possibly be true. MARK (V.O.) It is. ERICA (V.O.) What would account for that? MARK (V.O.) Well, first, an awful lot of people live in China. But here’s my question: FADE IN: INT. CAMPUS BAR - NIGHT MARK ZUCKERBERG is a sweet looking 19 year old whose lack of any physically intimidating attributes masks a very complicated and dangerous anger. He has trouble making eye contact and sometimes it’s hard to tell if he’s talking to you or to himself. ERICA, also 19, is Mark’s date. She has a girl-next-door face that makes her easy to fall for. At this point in the conversation she already knows that she’d rather not be there and her politeness is about to be tested. The scene is stark and simple. MARK How do you distinguish yourself in a population of people who all got 1600 on theirDEADLINE.com SAT’s? ERICA I didn’t know they take SAT’s in China. MARK They don’t. I wasn’t talking about China anymore, I was talking about me. ERICA You got 1600? MARK Yes. I could sing in an a Capella group, but I can’t sing. 2. ERICA Does that mean you actually got nothing wrong? MARK I can row crew or invent a 25 dollar PC. -
The Nature of Decentralized Virtual Currencies: Benefits, Risks and Regulations
MILE 14 Thesis | Fall 2014 The Nature of Decentralized Virtual Currencies: Benefits, Risks and Regulations. Paul du Plessis Supervisor: Prof. Dr. Kern Alexander 1 DECLARATION This master thesis has been written in partial fulfilment of the Master of International Law and Economics Programme at the World Trade Institute. The ideas and opinions expressed in this paper are made independently, represent my own views and are based on my own research. I confirm that this work is my own and has not been submitted for academic credit in any other subject or course. I have acknowledged all material and sources used in this paper. I understand that my thesis may be made available in the World Trade Institute library. 2 ABSTRACT Virtual currency schemes have proliferated in recent years and have become a focal point of media and regulators. The objective of this paper is to provide a description of the technical nature of Bitcoin and the reason for its existence. With an understanding of the basic workings of this new payment system, we can draw comparisons to fiat currency, analyze the associated risks and benefits, and effectively discusses the current regulatory framework. 3 TABLE OF CONTENTS Page 1. Introduction .............................................................................................. 4 2. The Evolution of Money .......................................................................... 6 2.1. Defining Money ................................................................................. 6 2.2. The Origin of Money ........................................................................ -
Banking Bitcoin-Related Businesses: a Primer for Managing BSA/AML Risks
Banking Bitcoin-Related Businesses: A Primer for Managing BSA/AML Risks Douglas King Retail Payments Risk Forum Working Paper Federal Reserve Bank of Atlanta October 2015 Revised February 2016 Abstract: To date, much of the attention directed toward Bitcoin has focused on its use as a preferred payment method by criminal enterprises because it allows users to transact pseudonymously. But Bitcoin offers more than just pseudonymity. It is a fast, low-cost, and secure payment solution that can also be used for many legitimate purposes. As investment and interest in the Bitcoin ecosystem have grown since its 2009 start, new businesses have emerged seeking to advance Bitcoin as a mainstream payment solution. The pseudonymous nature of Bitcoin transactions heighten Bank Secrecy Act (BSA)/Anti-Money Laundering (AML) Act compliance risks, making it especially challenging for these new businesses to establish banking relationships. This paper examines the current regulatory environment for Bitcoin-related businesses as well as measures these businesses can adopt to mitigate the BSA/AML risks inherent in the Bitcoin protocol. It also presents a framework for financial institutions (FIs) to consider for managing the risks associated with banking these companies. This paper is not a replacement, update, or supplement to BSA/AML guidance requirements provided in November 2014 by the Federal Financial Institutions Examination Council (FFIEC). By making a commitment to BSA/AML compliance, Bitcoin-related businesses can both better position Bitcoin as a mainstream payment system and enhance the ability of FIs to successfully bank them. The paper is intended for informational purposes and the views expressed in this paper are those of the author and do not necessarily reflect those of the Federal Reserve Bank of Atlanta or the Federal Reserve System. -
Creation and Resilience of Decentralized Brands: Bitcoin & The
Creation and Resilience of Decentralized Brands: Bitcoin & the Blockchain Syeda Mariam Humayun A dissertation submitted to the Faculty of Graduate Studies in partial fulfillment of the requirements for the degree of Doctor of Philosophy Graduate Program in Administration Schulich School of Business York University Toronto, Ontario March 2019 © Syeda Mariam Humayun 2019 Abstract: This dissertation is based on a longitudinal ethnographic and netnographic study of the Bitcoin and broader Blockchain community. The data is drawn from 38 in-depth interviews and 200+ informal interviews, plus archival news media sources, netnography, and participant observation conducted in multiple cities: Toronto, Amsterdam, Berlin, Miami, New York, Prague, San Francisco, Cancun, Boston/Cambridge, and Tokyo. Participation at Bitcoin/Blockchain conferences included: Consensus Conference New York, North American Bitcoin Conference, Satoshi Roundtable Cancun, MIT Business of Blockchain, and Scaling Bitcoin Tokyo. The research fieldwork was conducted between 2014-2018. The dissertation is structured as three papers: - “Satoshi is Dead. Long Live Satoshi.” The Curious Case of Bitcoin: This paper focuses on the myth of anonymity and how by remaining anonymous, Satoshi Nakamoto, was able to leave his creation open to widespread adoption. - Tracing the United Nodes of Bitcoin: This paper examines the intersection of religiosity, technology, and money in the Bitcoin community. - Our Brand Is Crisis: Creation and Resilience of Decentralized Brands – Bitcoin & the Blockchain: Drawing on ecological resilience framework as a conceptual metaphor this paper maps how various stabilizing and destabilizing forces in the Bitcoin ecosystem helped in the evolution of a decentralized brand and promulgated more mainstreaming of the Bitcoin brand. ii Dedication: To my younger brother, Umer. -
Eclipse Attacks on Bitcoin's Peer-To-Peer Network
Eclipse Attacks on Bitcoin’s Peer-to-Peer Network ∗ Ethan Heilman∗ Alison Kendler∗ Aviv Zohar† Sharon Goldberg∗ ∗Boston University †Hebrew University/MSR Israel Abstract While the last few years have seen extensive research We present eclipse attacks on bitcoin’s peer-to-peer net- into the security of bitcoin’s computational proof-of- work. Our attack allows an adversary controlling a suffi- work protocol e.g., [14, 29, 36, 37, 45, 49, 50, 52, 58, 60], cient number of IP addresses to monopolize all connec- less attention has been paid to the peer-to-peer network tions to and from a victim bitcoin node. The attacker can used to broadcast information between bitcoin nodes (see then exploit the victim for attacks on bitcoin’s mining Section 8). The bitcoin peer-to-peer network, which and consensus system, including N-confirmation double is bundled into the core bitcoind implementation, aka., spending, selfish mining, and adversarial forks in the the Satoshi client, is designed to be open, decentralized, blockchain. We take a detailed look at bitcoin’s peer- and independent of a public-key infrastructure. As such, to-peer network, and quantify the resources involved in cryptographic authentication between peers is not used, our attack via probabilistic analysis, Monte Carlo simu- and nodes are identified by their IP addresses (Section 2). lations, measurements and experiments with live bitcoin Each node uses a randomized protocol to select eight nodes. Finally, we present countermeasures, inspired by peers with which it forms long-lived outgoing connec- botnet architectures, that are designed to raise the bar for tions, and to propagate and store addresses of other po- eclipse attacks while preserving the openness and decen- tential peers in the network. -
A Solution Towards Eliminating Transaction Malleability in Bitcoin
J Inf Process Syst, Vol.14, No.4, pp.837~850, August 2018 ISSN 1976-913X (Print) https://doi.org/10.3745/JIPS.03.0101 ISSN 2092-805X (Electronic) A Solution towards Eliminating Transaction Malleability in Bitcoin Ubaidullah Rajput*, Fizza Abbas*, and Heekuck Oh** Abstract Bitcoin is a decentralized crypto-currency, which is based on the peer-to-peer network, and was introduced by Satoshi Nakamoto in 2008. Bitcoin transactions are written by using a scripting language. The hash value of a transaction’s script is used to identify the transaction over the network. In February 2014, a Bitcoin exchange company, Mt. Gox, claimed that they had lost hundreds of millions US dollars worth of Bitcoins in an attack known as transaction malleability. Although known about since 2011, this was the first known attack that resulted in a company loosing multi-millions of US dollars in Bitcoins. Our reason for writing this paper is to understand Bitcoin transaction malleability and to propose an efficient solution. Our solution is a softfork (i.e., it can be gradually implemented). Towards the end of the paper we present a detailed analysis of our scheme with respect to various transaction malleability-based attack scenarios to show that our simple solution can prevent future incidents involving transaction malleability from occurring. We compare our scheme with existing approaches and present an analysis regarding the computational cost and storage requirements of our proposed solution, which shows the feasibility of our proposed scheme. Keywords Crypto-currency, Bitcoin, Transaction Malleability 1. Introduction After its introduction in 2008 by Satoshi Nakamoto, the Bitcoin crypto-currency has gained significant popularity amongst other various crypto-currencies. -
Geraszimov-Doktrína – Egy Másik Megvilágításban
KATONAI NEMZETBIZTONSÁGI SZOLGÁLAT XVI. évfolyam 3–4. szám FELDERÍTŐ SZEMLE ALAPÍTVA: 2002 BUDAPEST 2017 A Katonai Nemzetbiztonsági Szolgálat tudományos-szakmai folyóirata Felelős kiadó Kovács József altábornagy, főigazgató Szerkesztőbizottság Elnök: Dr. Béres János vezérőrnagy Tagok: Dezső Sándor vezérőrnagy Dr. Magyar István ny. dandártábornok Dr. Tömösváry Zsigmond ny. dandártábornok Deák Anita alezredes Dr. Fürjes János alezredes Háry Szabolcs ezredes Dr. Magyar Sándor ezredes Dr. Tóth Sándor alezredes Dr. Vida Csaba alezredes Felelős szerkesztő: Deák Anita alezredes Olvasószerkesztő: Gál Csaba ny. ezredes Tördelőszerkesztő: Tóth Krisztina tzls. HU ISSN 1588-242X TARTALOM BIZTONSÁGPOLITIKA HOLECZ JÓZSEF ALEZREDES A GERASZIMOV-DOKTRÍNA – EGY MÁSIK MEGVILÁGÍTÁSBAN ...................................................... 5 BERTALAN DÁVID OGY. ALEZREDES A BIZTONSÁGI SZEKTOR SPECIÁLIS VONÁSAI .......................... 28 MEZŐ ANDRÁS ALEZREDES A DOKTRÍNAFEJLESZTÉS NEMZETKÖZI TAPASZTALATAI ... 45 HEGYI ÁGNES SZÁZADOS TERRORIZMUS A SZÁHEL-ÖVEZETBEN ....................................... 74 DR. GERENCSÉR ÁRPÁD KÖZÉP-ÁZSIAI SZÉLSŐSÉGES MOZGALMAK MEGJELENÉSI FORMÁI ÉS JELENTŐSÉGE .................................. 87 HÍRSZERZÉS – FELDERÍTÉS KOÓS GÁBOR NY. ALEZREDES – PROF. DR. SZTERNÁK GYÖRGY NY. EZREDES A FEGYVERES KÜZDELEM JELLEMZŐI KUTATÁSÁNAK FONTOSSÁGA, A HÍRSZERZÉS ÉS A FELDERÍTÉS JELENTŐSÉGE ..................... 97 DR. VIDA CSABA ALEZREDES AZ ELEMZŐ-ÉRTÉKELŐ MUNKA TERMÉKEI – NEMZETBIZTONSÁGI TÁJÉKOZTATÓK KÉSZÍTÉSE .............. 112 -
Bitcoin and Money Laundering: Mining for an Effective Solution
Indiana Law Journal Volume 89 Issue 1 Article 13 Winter 2014 Bitcoin and Money Laundering: Mining for an Effective Solution Danton Bryans Indiana University Maurer School of Law, [email protected] Follow this and additional works at: https://www.repository.law.indiana.edu/ilj Part of the Internet Law Commons, and the Law and Economics Commons Recommended Citation Bryans, Danton (2014) "Bitcoin and Money Laundering: Mining for an Effective Solution," Indiana Law Journal: Vol. 89 : Iss. 1 , Article 13. Available at: https://www.repository.law.indiana.edu/ilj/vol89/iss1/13 This Note is brought to you for free and open access by the Law School Journals at Digital Repository @ Maurer Law. It has been accepted for inclusion in Indiana Law Journal by an authorized editor of Digital Repository @ Maurer Law. For more information, please contact [email protected]. Bitcoin and Money Laundering: Mining for an Effective Solution * DANTON BRYANS INTRODUCTION Technology forges ahead at a rapid pace, whether we like it or not. Criminals recognize this inevitability and use technological improvements to advance their craft,1 committing crimes from half a world away in real time. Meticulous criminals also use technological advancements to distance themselves from their illegal activities and profits through use of virtual banking and electronic money transfer systems, which allow criminals to buy, sell, and exchange goods without any physical interaction. Though such services use digital logs that serve to identify a sender and a receiver’s digital identities, criminals possess the means to obfuscate their digital identity by simply spoofing their Internet Protocol address or by using another individual’s account, essentially making their activities untraceable.