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Bob The Magic Custodian



Summary: 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:

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:
See - all problems are solved! All we have to worry about now is:
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:
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:
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):



Thoughts?
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General info and list of exchanges for BUBBLETONE

We directly connect mobile network operators and end users globally on our blockchain-based marketplace. With Bubble Tone Blockchain, travelers can swiftly become legitimate local customers of any foreign operator in the country they are traveling to. They dont need to replace their SIM card, and they retain their home number. Travelers - Make calls and use data during travel worldwide at great local rates with direct connection to local operators - No need to change your SIM-card or phone number - Next generation messenger packed with amazing communication features User’s Interface part A brief demonstration how subscribers can be connected with local rates and LTE quality around the world. Operators and service providers - Any operator can become global without complex network integrations - Direct access to international telecom market with millions of new customers - Increase in revenue through distribution of value-added services Blockchain Telecom part Live demonstration of mobile carriers' interconnection via Blockchain. New Offers and Requests are created and broadcasted in real-time mode, and a new mobile profile was downloaded onto SIM-card of a subscriber. Bubbletone project consists of two main parts: Blockchain and Mobile App Bubbletone Blockchain Bubbletone replaces old-fashioned and costly roaming technology by implementing smart contracts into mobile operators' interactions. 1 Visited operator 1 Visited operator Any mobile operator can publish its own tariff plans as smart contracts ("Offers"). These Offers are visible to all operators and their subscribers Blockchain Subscriber 2 Request for mobile services abroad Home operator 3 Smart-contract ("Request") with Digital Identity hash and Financial Transaction Blockchain 4 It's enough to execute the smart-contract to receive money and identify a visitor 5 Servicing the subscriber directly by downloading its own mobile profile onto a SIM-card "over-the-air” Any mobile carrier can publish prepaid plans as smart contracts on Bubbletone Blockchain. These offers are visible to all other operators and their subscribers. When subscriber selects offer, a new smart contract is created with the subscribers digital identity and payment transaction directly to foreign operator. Sim card registered in the local mobile network Subscriber is authorized Payment is processed Service is provided Billing is transparent Tariffs are local Zero costs for operator Quality LTE / LTE+ Quick launch for operator Bubbletone GitHub Bubbletone Yellow pager Blockchain in Telecom Wiki Why big operators will join Bubbletone? Read on Medium Bubbletone App Direct connection to a local operator provides low rates and high LTE quality, with easy management using Bubbletone mobile app BETA version is already availabe in: Google PlayApp Store Marketplace connecting subscribers and local network operators globally Keeping domestic phone number during foreign trips Conference video and audio calls SMS in future - send a date and text for your SMS Burning messages Buy, keep and use domestic phone numbers in different countries 100+ other communication features Who we are: 20 years of experience in Telecom Industry Allo Incognito - our own medium-sized mobile operator in Russia since 2002 Allo Incognito Website 240k+ Premium Subscribers 42m USD Annual revenue 10k POS Bubbletone is trending
UMT Tokens 22% Network Development Fund 220 000 000 UMT 50% Crowdsale 500 000 000 UMT 20% Founders 200 000 000 UMT 7.8% Team & Community Development Fund 78 000 000 UMT 0.2% Bounty fund 2 000 000 UMT Name: UMT Type: ERC-20 Function: Used in smart contracts to perform transactions. Can be used to top up user balance to pay for telecom services Total Supply: 1 000 000 000 tokens For sale: 50% All unsold tokens will be burnt and additional release of tokens will not be possible! Checked by clearify Bubbletone ICO 01.02 10.02 Stage 1 10.02 01.03 Stage 2 02.03 10.03 Stage 3 20.04 15.06 ICO Stage ICO ETH/UMT 1 ETH = 4000 UMT Vesting No vesting Minimum 0.1 ETH ICO starts: 20.04.18, 10AM (London time) Token price: 1 ETH = 4000 UMT Hard cap: 15 000 000 USD Accepted currencies: ETH, BTC Join White List to reserve your UMT Tokens JOIN WHITE LIST Our Team Key Team
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Dr. Norman Lewis Telecom expert Norman was running PWC’s innovation programme, He also worked in Orange UK as a Director of Technology Research, Founding Director of Future-Diagnosis, Executive board member of the MIT Communications Futures Programme.
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John Mun Co-Founder of Linker Coin; John obtained his MFE at UC Berkeley, then became a Market Maker, HFT trader and General Manager at one of South Korea's leading investment institutions Woori Investments and Securities. John’s finance and engineering background supported him strongly in the blockchain industry and now is also an expert in Smart Contract development.
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Oleg Khokhlov is Partner with international law firm Goltsblat BLP, the Russian practice of Berwin Leighton Paisner (BLP), headquartered in London.
Oleg was selected by peers for inclusion in The Best Lawyers in Russia 2013-2018 Editions in the field of Banking & Finance Law. He has been also highly recommended for Banking & Finance by IFLR1000 and Legal 500.
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Maria Agranovskaya Blockchain and ICO Legal Expert. Managing Partner of GRAD Attorney Bar (30+ lawyers). Attorney at Law with 20+ years of experience. Working with cryptocurrency since 2010: ICO, trading, funds setup, etc. Over eight years running a multifamily office. Cross-border transactions, investments, asset management, deal and corporate structuring in various jurisdictions. M&A, international taxation Tech and Telecom leaders about Bubbletone Blockchain Roadmap Q1’2018 Initial version of smart contracts is ready.
The first “Offer” and “Request” are on the Blockchain platform. Demonstration of the platform at Mobile World Congress in Barcelona (February’18). Integration with major eSIM platforms to download mobile profiles onto SIM cards
Q2’2018 Web-API for integration of mobile operators and service providers.
Integration of Digital Identity into Bubbletone app. Commercial launch, with “Offers” from 10+ mobile operators are on Blockchain, low rates in 80+ countries.
Q3’2018 Global Mobile Profile approval by International Telecommunication Union.
Update Mini Nodes to participate in processing smart contracts. BubbleTone Blockchain – White Paper Page 25 of 31 New features in the Bubbletone app: Voting platform based on Blockchain, 4K videoconferences, transfer of fiat money and crypto currencies
Q4’2018 Expanding list of mobile operators and service providers connected to Bubbletone Blockchain Ecosystem.
The first 1 million transactions are processed
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First prototype of a global SIM-chip to be embedded into mobile devices. Expanding list of mobile operators and service providers connected to the Bubbletone Blockchain Ecosystem. 10 million transactions are processed
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Bubbletone Community around the world Bubbletone Worldwide Tour Past Events May 14-16 TMForum, Nice, France May 14-16 Coindesk Consensus 2018, New York, USA May 2-3 Future Blockchain Summit, Dubai May 1-3 IOTX 2018, Dubai April 26-27 World Blockchain Summit, Moscow, Russia April 23-26 MVNO World Congress, Madrid, Spain April 18-19 Blockchain Expo, London, UK April 17-18 Blockchain Conference, Moscow, Russia April 16-17 World Blockchain Forum, Dubai April 8 Blockchain Tomorrow 21, Seoul, Korea April 4 Blockchain Conference, Berlin, Germany March 28 Blockchain Conference, Tel Aviv, Israel March 22 Tallinn Blockchain Conference, Tallinn, Estonia March 21-22 Cryprocurrency World Expo, Berlin, Germany 26 February - 01 March Mobile World Congress in Barcelona March 10 Crypto Investor Show, London, UK March 7-8 Blockchain Summit Zurich 2018, Zurich, Switzerland March 3-6 D10E Fintech Conference, Seoul, Korea March 2 Bubbletone Meet-Up, Singapore March 1 Blockchain & Bitcoin Conference, Istanbul, Turkey February 23 7th Korea Blockchain Symposium, Seoul February 27-28 Singapore Blockchain Summit 2018, Singapore 25-26 January Cryptoeconomy ICO London 22-24 January London Blockchain Week 2018 14 December Big ICO Roadshow, Moscow, Russia 8 December Crypto Space, Moscow, Russia 29-30 November Blockchain Expo in Santa Clara, California (booth 419) 29-30 November Block Show Asia in Singapore 14-15 November Telecom Conference in London 24-25 October World Blockchain Summit in Dubai 8-12 October GITEX Technology Week in Dubai, Stand E3-6 3-5 October Blockchain Solution Forum in Barcelona, Stand №100 26-27 September Telecom Conference in Singapore 25-26 September World Blockchain Forum in London FAQ How can I buy your tokens? Which cryptocurrencies are accepted? Which wallet should I use to receive tokens? What is the goal of your project? Is your product already working? Do you have a prototype or a beta version? Why do you have a blockchain in your project? How is your system going to expand? What are advantages for Node owners? What are the advantages of BubbleTone messenger? How do I operate all these other Sims on my phone? JOIN US
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