Jake Chervinsky, General Counsel at Compound, and Rafael Yakobi, Managing Attorney for the Crypto Lawyers, discuss regulatory arbitrage, new laws affecting Bitcoiners, and the biggest regulatory threats to Bitcoin.
05:30 New Bitcoin Regulations
08:21 Travel Rule Implications
11:55 FINCEN Proposals and Concerns
13:53 Lowering Thresholds v.s Expanding Requirements
16:07 Potential Problems with New Rules Requirements
18:00 Effects on Financial Privacy
22:08 FATF Functionality and Global Impact
27:45 Bitcoin and Legal Attack Vectors
34:50 On the Topic of Privacy
47:00 Privacy and the Lightning Network
51:07 The War Against End-to-End Encryption
54:00 Cypher Punks Write Code
59:39 Legal Action Against BitMEX
1:10:00 Closing Thoughts
1:13:36 SSL Sign-Off
Everyone, welcome back to Swan Signal Live. It’s another Tuesday. It’s another day for talking Bitcoin here on Swan Signal Live. This is a production of Swanbitcoin@swanbitcoin.com, the best safest and easiest way to stack sets. This course is a weekly show, and it’s brought to you by Swan Bitcoin, and we put together guests for compelling discussions. We’ve got two great guests for you today to talk about Bitcoin and law. This is something that we don’t talk about enough as Bitcoiners. We’re going to get into a great conversation. There’s going to be a lot to learn for me and for you as well. Before we dive in, let’s talk a little bit about Swan. We’re going to check in quickly. We have lots going on at Swan. We just launched Bitcoin TV last week.
You’ll find that at bitcointv.network, or on our YouTube channel at youtube.com/SwanSignal. We have over 10,000 unique viewers of it so far just in the past week. There’s usually about 50 Bitcoiners hanging out there, chatting and watching what we have on. We are adding new content to it all the time. We’re finding the best stuff available on the web, curating it, organizing it, putting it together in an order that we think makes sense. We have some fun like hype videos that run in between amazing videos by Alex Gladstine and Safa Dean and all the great Bitcoin thinkers and speakers out there. Tons to learn. It’s fun just to lay back and watch and learn and absorb all that great Bitcoin contents.
In Q1 next year after we get this thing nailed down, we’re going to launch on Pluto TV, Roku, and Samsung, over the top TV networks like those. I can’t wait to see what becomes of Bitcoin TV, really excited about it. We have lots going on in the product as well. By now, we’ll be launching soon of course. We have been the way to stack sets, is what we were focused on is just steady accumulation of Bitcoin, and that is not going away. That is still the best way to invest in Bitcoin over time for 99.9% of you. If you are not a professional trader, you should not be trying to time the market and stacking set steadily is the way to do that. But every now and then you want to add a little bit to that stack. You want to buy right now.
So we’re going to add that buy now button. You can join in as a Swan member and help us test that out at swanbitcoin.com/buynow. Sign up for that beta. All right, stay tuned. We have lots of other exciting product announced coming the next few weeks. There’s a lot going on. We’ll keep you informed here. All right, let’s dive into this episode. Today we have Jake Chervinsky and Rafael Yacobi with us. They’re both lawyers who are experts on laws and regulations applicable and adjacent to Bitcoin and cryptocurrency. As I said at the top, in general, we as Bitcoiners, we talk a lot about the economics and technology of Bitcoin, the potential benefits for society but, and I’m sure both of our guests will agree, we don’t as Bitcoiners talk or think enough about the legal and regulatory environment in which it exists. That’s what we’re going to do today. Jake, Rafael, welcome to Swan Signal Live.
Thanks for having us.
Yes, thank you for having us.
Absolutely. Jake, it’s been a big year for Bitcoin in general, also a big year in terms of developments in the legal and regulatory framework that it lives within. Lot has happen, positive that we can construe positively in the United States with governments warming up to Bitcoin in various ways. Also, some looming possible negatives out there as well. I want to talk about all of those today, but let’s start off with the big thread that you dropped. It’s got one and a half … 1.6 thousand likes. I think it was super informative, and it’s something that we need to talk about here because it’s flown under the radar for a lot of Bitcoiners and I’d love to get into the details here. We are set up with this travel rule suggestion, or I guess a recommendation, from the FATF, the Financial Action Task Force, and we had to first of all get into what the hell that is and how it came to be. Then talk about this travel rule and how it might apply to Bitcoin.
Yeah, definitely. There’s a lot to unpack here, but let me try to set the stage a little bit for why this issue is so important. I think we’ll all agree that Bitcoin is fundamentally important because it’s an asset that we can hold on our own without having to rely on trusted third parties to create it, to store it for us or to process transactions for us, right? This is why we always say not your keys, not your coins. You want to take possession of your own Bitcoin so you don’t have to rely on any trusted third parties. Without that core concept, Bitcoin isn’t really worth a whole lot. What we don’t want, although we love institutions like Swan Bitcoin, we don’t want to have to rely on them to hold our assets, our Bitcoin for us or process Bitcoin transactions for us.
The thing is that concept of a peer to peer electronic cash system is somewhat inconsistent with the regulations that apply to traditional financial institutions. We’re talking about the Anti-Money Laundering and Countering the Financing of Terrorism regulations, which essentially require regulated financial institutions to conduct financial surveillance over all of the transactions that they process for their customers, and also to perform customer due diligence. KYC is how it’s usually referred to, know your customer requirements, where those institutions have to figure out who their customers are in the first place. Unless you comply with all of those requirements, then the financial institution could violate the law and be in trouble with an enforcement agency like FinCEN, the Financial Crimes Enforcement Network here in the United States.
What we’ve been seeing recently, and this is what motivated me to write that thread to let everyone know what’s happening in the regulatory world right now is some interest among regulators in restricting the ability of customers of those financial institutions to withdraw their Bitcoin from the exchange or from a custodian to their own wallet where they can actually own and hold their own keys. So we can get into a little bit more about the technical issues and how this is rolling out, but really the problem that we’re starting to run into is regulators being concerned about self custody and privacy, and as a result, considering some new regulations that would make it harder or even impossible for people to hold their own keys.
Rafael, what was your reaction to this potential travel rule situation and its implications on Bitcoiners’ self-custodying and self sovereignty, which is why a lot of us are here?
Sure. Well, I think Jake put together a really good background that helps provide a lot of good context here, but just it might be worth repeating generally what the travel rule is. The travel rule applies to transactions between financial institutions, and Jake feel free to correct me on any of this, but it applies specifically on transactions taking place in between financial institutions and requires that, under certain conditions, they have to collect information and share information in between institutions. FinCEN is in the process of putting forth proposed rule making which would change the rules and reduce the threshold for when the travel rule applies to $250 for international transactions down from $3,000. I think it’s a concern, but I may … I see some silver lining in reading the proposed rule making because they talk about that … Of course, the lower threshold is negative and hard to justify for me.
I mean, I really can’t see what people would be doing with $300 that could be so bad that dragnet surveillance is necessary. But one thing I remember reading in the proposed rule making is that there would be this reason to know standard, which would mean that it’s not like the institutions have to collect all this information for every transaction, for every wallet all the time. It would only apply if there’s a reason to know that this is an international transaction. Now, this isn’t saying that this is a good idea, but this is just trying to, well, find some silver lining there. Given that there’s going to be this reason to no standard, it’s like there’s going to be some plausible deniability for exchanges and for any financial institution where if you’re withdrawing Bitcoin to your own wallet, for example, the travel rule doesn’t apply anyway.
So they would have to have some reason to know that you’re sending money internationally, and from user’s point of view, you can just withdraw Bitcoin to your own wallet, right? Then the travel rule doesn’t apply anyway. Even if you’re going to send it internationally afterwards, you should always just withdraw to your own wallet, and then wherever you’re going to send the money, the Bitcoin afterwards, just send it there from your own wallet. Obviously some exchanges will be tracking what you’re doing, but it won’t be their responsibility anymore. So it’s also worth keeping in mind that this proposed change isn’t specific to crypto. They did mention crypto and say that it does apply to crypto as well. But this is for financial institutions in general, and with traditional financial institutions, you’re telling them who to send the money to.
So they’re always going to know if it’s international, almost always, right? Either you’re sending it to an account number at a bank, in which case they know it’s an international bank, or you’re giving them an address or you’re giving them the person’s name and social security number or whatever it is, right? So I don’t see it changing so much immediately for crypto. Of course, it might be evidence of bad things to come in the future and it’s very incremental. There’s risks down the line, but I don’t see this particular change for a lot of Bitcoin businesses making too much of a difference, mainly because you can just withdraw to your own wallet, which you should just do anyway.
Yeah. I think that’s right. Just to make sure we’re clear about exactly what proposals and potential regulatory changes we’re talking about, I want to be clear about what Rafael is describing and then what the bigger concern is that may come down the road but it isn’t being considered right now. Rafael was talking about a current notice of public rule making that FinCEN issued saying that they want to change the travel rule to reduce the threshold for the requirement of sending information about the customer and the nature of the transaction between financial institutions from $3,000 down to $250. What that means is let’s say you want to send Bitcoin from Swan Bitcoin to some other exchange or some other custodian.
Swan Bitcoin, as a regulated financial institution, is required to send information about you, the person sending your Bitcoin, and some other information about you to that other financial institution which will then be required to maintain that information. That’s part of the way that the anti-money laundering regulations ensure financial surveillance over all kinds of transactions no matter where in the world these financial instruments move, whether it’s Bitcoin or something else like US dollars in a traditional bank account. Honestly, I agree with Rafael. I don’t think that’s that big of an issue. I do think that it’s the wrong direction. I think what that does is it expands the amount of financial surveillance that regulators are doing by capturing transactions that are of a much lower dollar value and pose much less money laundering or terrorist financing risk.
Basically what we’re doing by agreeing with that reduction in a threshold is saying we’re going to give the government way more information about us and about our financial transactions, we’re going to sacrifice our privacy to some extent, without really having a whole lot of benefit for the government in terms of them trying to detect or prosecute crimes or terrorist activity. But honestly, it’s not that big a deal because, like Rafael said, you can and should withdraw your Bitcoin to your own wallet anyway, right? Not your keys, not your coins. The bigger question is whether regulation will stop with just lowering that threshold, but still saying the travel rule only applies to transactions between financial institutions, or whether the next thing the regulators will do right next year or in two years, or at some point down the road, is say, “You know what? We actually want to expand the travel rule as well.”
We want to change it to say even if you are conducting transactions between a financial institution on one side and a self hosted wallet, like a hardware wallet or a paper wallet, or some way in which you, the user of Bitcoin is going to hold your own keys, they might say, we think that those regulations should apply there as well, and the user should somehow prove that they own that hardware wallet, or we should be able to monitor or surveil transactions with that hardware wallet or paper wallet, or what have you. That’s not something that is required currently under US law. It is unfortunately something that we’re seeing happen in some other jurisdictions.
So in Switzerland, for example, the Swiss government is now requiring Swiss financial institutions to switch Bitcoin exchanges and custodians to verify the owner of a self hosted wallet before they allow transactions with that self hosted wallet, which I think is very much a restriction on the freedom of users and customers of those exchanges and custodians that we shouldn’t put up with. Just today we saw the Netherlands implement a similar requirement. My fear and the reason that I wanted folks to start thinking more about that issue is that that could become a global standard so that you, as a customer of Swan Bitcoin, will have to prove that your ledger hardware wallet or your treasure or whatever you have belongs to you just in order to take possession of your own Bitcoin, and that’s a problem.
That is a big problem potentially. That’s happening already in Switzerland. Swiss Bitcoiners have to basically proclaim and attach their identity to specific wallets addresses. How are they implementing it? Do you know?
Yeah, so what the requirement says is the exchange has to, “Verify the beneficial owner of the unhosted wallet.” That’s the word that they use to describe someone’s own wallet. The problem is there isn’t really a clear way that an exchange can do that, right? How do I prove to you that my hardware wallet belongs to me or that I’m in possession of it and not somebody else. The unfortunate result of this in Switzerland is that exchangers have basically said, “We don’t know how to comply with this requirement. So we’re just not going to allow any transactions with self-hosted wallets. It’s easier that way, and then we don’t have to worry about compliance.” What that means is Bitcoin is essentially stuck in a custodial world where customers of those exchanges can not take possession of their own Bitcoin.
In the Netherlands, I think there was an exchange today that announced that they will allow people to take a picture of their wallet and then sign a message from the address that they want to withdraw to. So maybe that works, but I think it’s very unclear. For me the concern is this is really just a smoke screen for government trying to stop people from taking possession of their own Bitcoin, and it sounds like, well, all you have to do is verify the beneficial owner of the hardware wallet. There must be a way to do that, but they know it’s really very difficult and it will result in fewer people taking ownership of their own Bitcoin.
Interesting. Rafael, this is really concerning potential attack vector against Bitcoin’s proposition as money that’s outside of the legacy financial system and their control. Do you see this happening? What are the prospects for this happening in the United States, do you think?
Well, I thought it was interesting that I didn’t know too much about how the Swiss firms were reacting to this rule, but I thought it was interesting that you said that they’re not allowing withdrawals to self-hosted wallets, at least temporarily because we had a similar situation here with the travel rule where even though it seems relatively clear that it applied to crypto, there wasn’t any way to comply with it for exchanges, right? There’s various companies and collaborations that are working on solutions, but the response here was just not to do anything, right? If you didn’t have a means to be able to know where the Bitcoin is going and who to send the information to, if you’re supposed to send information to another exchange, you just don’t do it because there’s no tools to do it, there’s no mechanism for doing it.
I think that’s a reflection of our rebellious American spirit, which I’m very happy about, that the response was to ignore rules that are impossible to comply with instead of burdening the users with the punishment of not being able to comply. But as far as seeing that happen here, well, I can’t say that I’m super optimistic about the future of financial privacy, but I don’t see the same kind of interest and willingness here for that immediately, although it seems like it’s the logical extension of what other nations are doing and your privacy is bad according to the government, basically. If your privacy is bad, then you shouldn’t have it and you will not have it. That’s the direction that we’re heading.
How soon that will happen and how it will happen is a little bit more challenging to predict. But I do want to give FinCEN some credit for knowing what they’re talking about, for the most part, in the guidance that they’ve put out, which shows that they, at least to me, understand how Bitcoin works relatively well. There were some things about the guidance that they put out that maybe were contradictory or didn’t make as much sense as they could. But in general, they were able to recognize things like the difference between anonymized cryptocurrencies and Bitcoin and self-hosted wallets and custodial wallets. I’m happy about the fact that they understand what they’re talking about, and the hope is that they can get the right information to make logical, thoughtful decisions
In general, although the US leads the international push against financial privacy, I still have some faith that they’re not going to rush through some kind of new rule that is going to be extremely problematic for the industry, but the trend is still the same, right? Incremental decreases in your privacy and the fact that the financial thresholds that usually apply to these kinds of rules never change. So even though we have inflation, they never seem to be adjusted for inflation.
Meanwhile, the penalties, for example, that you get for noncompliance are adjusted for inflation, which I thought was an interesting contrast. I mean, I think it’s been a while since I read about it, but I think that the $10,000 rule for currency transaction reports has been the same for I don’t even know how many years, right? The value of that inflation adjusted dollars is five times as much. It used to be, if you went into a bank and you deposited 60 grand, for example, that they would have to make a report, and now it’s 10 grand, right? Now they want to reduce the travel rule to 250. I mean, it’s absurd. What can you get for 250 bucks anyway?
Yeah. Yeah. I’m curious to know what is the Financial Action Taskforce, and how did it come to exist? It hasn’t been around forever. It seems to be … I think, when I looked it up on it, it’s been around for 20 years or something. I mean, are these just recommendations being issued by a group of countries, representative of certain countries? Then how often are these suggestions actually adopted by the countries? Is there any incentive or disincentive for people to … for these countries to adopt the recommendations from the FATF?
Yeah, so the FATF, the Financial Action Task Force is an international standard setting body that has about 40 odd, a few more than that, member jurisdictions. It’s basically a group of countries that get together to talk about what best practices are and what the industry standards should be for anti-money laundering regulation. It’s important to note that the FATF doesn’t make the law, it just makes recommendations for what its member jurisdictions should or should not do with their own laws. I’m not totally sure about exactly how it arose, what the details are around that, but I will tell you that as the financial system has become digitized in the last few decades, there has been a lot more attention paid to anti-money laundering regulations and bringing as much of the world’s financial system under the scope of financial surveillance as possible.
The FATF is part of that effort to make sure that there aren’t, for example, offshore banking havens like there was for quite a while in Switzerland, where people can escape this realm of financial surveillance and hide their assets from either tax authorities or from law enforcement. The FATF basically makes recommendations for what its member countries should do. Not all of the member countries agree with what the FATF’s recommendations are. Also, the FATF makes its decisions based on the representatives who are sent to the FATF by the member countries. So it’s the treasury department here in the United States that sends a representative to the FATF to try to work out what these industry standards should be.
The thing is some of those standards are legal changes that have to go through Congress in the US, right? That the treasury department can’t implement on its own. Sometimes you would need the House and Senate to agree on some type of change in order to bring the US into compliance with a FATF recommendation that Congress might not agree with treasury about, or the treasury, frankly, might be in the minority among FATF and not agree with what FATF’s recommendation is. While the FATF is very important in making recommendations that we assume are going to end up the global industry standard, it isn’t the be all end all for what the law will be in any particular country.
I think here in the US, frankly, we put more of a premium on individual liberty and on financial freedom than some other countries do. I think, frankly, it’s a lot easier for some European countries, a country like Switzerland, to have an onerous restriction on exchanges that eliminates the possibility of people taking possession of their own assets that they should, by all rights, be able to control however they want because they own those assets. I think that might be harder in the US than it is in some other places.
Well, that’s good to hear, and that thanks for laying out to me. I wasn’t exactly sure how the FATF worked. Do they have any mechanism by which to compel nations to adopt one way or the other? Or is it just by group, I guess … I mean, it’s just peer pressure almost, is what I guess what I’m looking at. Is that how this work?
Yeah. I could speak to that just a little bit. So they keep various lists of countries, and then if you don’t do what they want, then they put you on the bad list. Then if they put you on the bad list and there’s this social pressure or some kind of financial pressure where if you’re on the bad list, then you can’t make deals or do financial transactions with another country that has agreed not to do deals with people that are on the bad list. Right?
So you’re limiting the financial opportunities for the citizens of your nation if you don’t comply. Right? I thought it was interesting that they have a presidency that switches every year or two years or something like that, and their last president was from China, who is the last country that I would want in charge of any kind of surveillance program, although I don’t doubt their effectiveness. That’s why I don’t want them to charge because they’re a little bit too into it.
Yeah. I mean, I think that’s probably like most nation states these days. We are in a world now where we are seeing more and more financial regulation, more and more I guess using the financial system as a way to spy on people, as a way to enforce behaviors and laws. We, as Bitcoiners, look to Bitcoin as a beacon of hope for a way to opt out of a financial surveillance system, it seems that we will get the full brunt of the financial … the financial government complex coming down on Bitcoin. As you guys are … I would assume that this would happen mostly through regulatory frameworks and legal and regulatory frameworks as that is the probably most effective way to attack something like Bitcoin or free money like Bitcoin. Jake, what do you think is the … I mean, this is one rule, the travel rule is one. But what are some other vectors of illegal attack on Bitcoin?
Yeah, I think that’s right. I mean, I do think that it will be harder for regulators and policy makers to attack Bitcoin than we might be making it sound, right? I will freely admit that I’m a little bit of an alarmist on this issue, because I think it’s so important, it’s so existential to the point of Bitcoin that it’s worth being a little bit alarmed about.
There are other people who will tell you, right, it’s not quite so much of a worry and the policymakers are less likely to attack. I just want to put some minds at ease in case folks are worried about that. I do think that the world of Bitcoin that a critical hostile government would accept is a world of forced Bitcoin banking, where you basically treat Bitcoin just like the US dollar where transactions are only allowed between regulated institutions, where because Bitcoin users don’t control their own private keys, the government can censor transactions, can surveil transactions, will know the identity of all of the users of Bitcoin. Now, is this actually possible? I would say as a practical matter, of course it isn’t, right?
The government can’t regulate Bitcoin, but blockchain, and there will always be people who use it outside of a financial system that has the stamp of approval from government. But I do think that what we would look at is, number one, these restrictions on allowing people to take Bitcoin off of custodial platforms and into their own wallets, that could look like the travel rule implementation that we were just talking about where an exchange has to verify the owner of the hardware wallet which might discourage some folks from withdrawing Bitcoin. It also might give the government an upper hand in tracing transactions on the Bitcoin blockchain, which is a separate issue that we should get into, the blockchain analytics question.
It also could look like restrictions on the amount that you can withdraw in a given day or a given week. We actually see some companies that impose restrictions right now. Cash App, for example, I think only allows a few thousand dollars of withdrawals per week. It could be something that looks more like that. It could be a reporting requirement. So the government could say that every time an exchange allows a withdrawal to a self-hosted wallet, they have to file a report with the government telling the government that this has happened and who the person was and how much they withdrew or something of that nature. I think those are all the attack factors that we would imagine.
I don’t think that we’re in a world where government would ever try to ban or illegalize possession of Bitcoin. I just think that that adoption is too widespread now, right? We have too many hedge fund managers and investors and pension plans and folks who are excited about and interested in buying Bitcoin for us to have a 6102-like event, right? 6102 referring the executive order where possession of gold was illegalized in the 1940s. But I do think we could see an effort to create basically a wall to garden where Bitcoin is just another financial instrument that government can control just like any other, and that’s what we have to watch out for and advocate against.
Yeah. Rafael, anything to add to that? So some color or some other ideas for attack vectors?
Sure. I think those are all great points, and this might sound strange, but I’m hesitant to speak my nightmares out loud because I don’t want to give anybody any suggestions. I mean, I understand it makes sense to prepare for what might happen, but part of me feels like there’s some kind of strategic advantage to not telling our enemies, you could call them, exactly how they can defeat us, so to speak, and maybe that’s me speaking more as a Bitcoiner than a lawyer. But I’m skeptical about that, and what I try to think about and focus on might be more best practices that you can take given the current situation, right? Rather than outline the worst case scenario, but Jake has done a good job of covering that, although there’s one or two terrible things I can think of that I don’t even want to talk about.
We’ll have to just let those ruminate. But as far as best practices, since it’s still responsive to the question hopefully, you had mentioned earlier about Bitcoin being a way to escape financial surveillance. I actually don’t know if that’s what Bitcoin is able to do. I mean, it can under certain circumstances, depending on how you use it. For example, if somebody pays you in Bitcoin, there’s no reporting obligation. You don’t have to collect their information, right? Just the same way that if you go to a store and buy some food, there’s no real information collection happening there. That way, you can use it relatively privately, right? Yu can use CoinJoin or things like that. But if you’re going to interact with financial institutions and traditional fiat on-ramps, then Bitcoin is not the way for privacy, right?
I don’t know that Bitcoin was designed to solve that issue, or this has obviously been an ongoing debate about Bitcoin privacy, right? Whether or not it should have been more private or how can we make it more private and what problems is it really solving? It certainly solves, to me, the scarcity problem, right? And not being able to be debased. That part is set in stone for practical purposes and very clear, but it’s not clear to me that Bitcoin is the way to get financial privacy, although it certainly is better than fiat currency in that regard. But, well, I would say I would encourage people to earn Bitcoin, not to discourage them necessarily from using Swan. Swan is cool, but if you want to opt out, then you need to opt out and not interact with entities that are under the control of government and effectively agents of the government for purposes of information collection.
Sure. Yeah. You bring up a good point of discussion that I want to get into, which is privacy, and Jake was referring to it earlier with the blockchain analytics. I know both of you have done work in this area and studied it, and I would love to dive into that conversation now. I saw in … I think it was a BIS report in that thread that you posted Jake. They referred to a set of cryptocurrencies called Anonymity Enhanced Cryptocurrency, AEC. It’s a way to separate something like Monero, I suppose, from Bitcoin. They also claim in that same report that full anonymity is not possible.
Just flat out say that, right? Bitcoin is not completely anonymous. It is pseudonymous blockchain analytics to allow law enforcement to enforce laws through the tracing of transactions. We’ve seen it happen over and over again. There’s many high profile cases we can point to. First of all, do you think that Bitcoin would be in a much different position now from a regulatory standpoint in terms of its relationship with the law and the government if it were fully anonymous on the base layer?
Yes. Unequivocally definitely yes, and I think it’s important to know there’s basically two main concerns that governments broadly speaking have about Bitcoin. One is the threats to their monetary sovereignty, right? The idea that Bitcoin is going to supplant the US dollar as the global reserve currency, and it’s going to destroy the value of all fiat currencies, right? Bitcoin is a black hole that sucks in all value, right? We all, I think, are pretty interested and excited about that idea. Governments, frankly, just being honest, they don’t take that seriously. They’re really not very worried about Bitcoin being a monetary sovereignty issue. They’re actually more worried about stable coins like Tether or USDC as a monetary sovereignty threat. So set that aside for a second.
The second biggest concern that they have though is this money laundering and terrorist financing risk, right? They’re concerned that they cannot control the flow of funds between individuals, right? The censorship resistance and also the privacy that a public blockchain like Bitcoin can enable. They want to know who has money, they want to know where they’re moving in, they want to be able to stop those transactions, and they want to be able to seize those assets whenever and wherever they please, when they think that there’s some illicit activity going on. That’s what they’re really worried about when it comes to Bitcoin. The thing is, as you said, Bitcoin really isn’t that private.
There are ways of trying to obscure transactions in Bitcoin like CoinJoin. The truth is, and again I hate to be the bearer of that news, analytics companies are actually very good at unwinding CoinJoin and other types of mixing transactions. It’s really not private. Because of that, governments tend to be much more concerned about other cryptocurrencies that really are private, right? Things that they really cannot trace. Basically, that comes down to Monero and shielded Zcash transactions. Those are the ones that they’re most concerned about. What we see is attempts by government to limit access to those cryptocurrencies, even in this world of walled garden of regulated financial institutions that still have to do customer due diligence and transaction monitoring.
What happened, that you referenced, I wrote about in my thread, was the Department of Justice basically saying to exchanges in slightly different words, but the point being, we do not think that you can comply with the law if you allow access to “anonymity enhancing cryptocurrencies.” Then as you mentioned, the BIS, in talking about CBDCs, Central Bank Digital Currencies, basically said anonymity is a non-starter. We cannot have anonymity because we need to know who is transacting and be able to trace their transactions and stop them from committing crimes. I do think, if Bitcoin were more private, we would see that same kind of approach from the Department of Justice, which is to say, we’re just not okay with this technology existing, and we’re going to try to stamp it out wherever we can.
To be honest, that’s what they’re trying to do with end-to-end encryption. Not to go on for too long, but recently the five eyes, which is a group of five different countries that cooperate on surveillance matters, recently put out a statement basically attacking encryption, the very concept of it, almost as a throwback to the ’90s crypto wars. We still haven’t resolved that question about the ability of people just to use end-to-end encrypted systems.
Yeah. Rafael, do you want to comment on the question about Bitcoin and its base layer and privacy level and whether or not that’s basically the reason that Bitcoin still exists? I feel like it would have been attacked a lot earlier and a lot harder way more like Monero than it is. Then let’s talk a little bit more about this end-to-end encryption thing, but first are comments on Bitcoins base layer and privacy.
Sure. I was thinking through it while you guys were talking about how things would have been if Bitcoin was totally private, right? Mandatory on chain privacy, like Monero but without Monero’s scaling problems or being able to … challenges with verifying the total supply or inflation bugs, things like that. Right? If Bitcoin was just like Monero minus those issues. Right? It seems like it would have a lot more negative publicity and probably a number would probably not go up so much. That would be my guess as the difference. Right? There’d be less exchanges available, less institutional adoption, right? I don’t know that it would have failed. I mean, Monero has managed and in spite of this potentially bad publicity, but it certainly wouldn’t be as widely accepted as it is now.
That being said, I did want to make a comment about the blockchain surveillance companies and CoinJoin. I’m not a technical expert on this and neither is Jake, although he might know a lot about it. But there’s two points to make there. One is, I don’t know that we’re always able to know for sure how well the blockchain analytics companies are doing, right? Because their claims about their abilities to track and trace things are a little bit self-interested, right? If they proclaim what a good job they’re doing, then it can help them sell their services to their potential customers and to governments and anyone else who might want to buy them. Right? Obviously if they said, “Well, we really can’t trace certain kinds of transactions,” then their services are not that valuable.
I’m not in a position to do blockchain analysis myself to debate how effective they are, but that’s something that I just keep in mind when I read press releases like we can track Monero or whatever, which I remember saying and I don’t know if there’s any truth to that at all in practice. But as far as CoinJoin goes, that’s certainly a hot topic and I’ll leave that to lots of other people that love debating about it. But I’m hopeful and confident, sort of confident, that the tech will remain ahead of the law and will remain ahead of the people trying to track it, right? I’m hopeful that people that build tech are able to build interesting creative innovations that take time to unwind before they get found out.
I’m optimistic that they can stay permanently ahead of the chain analytics companies. Now, of course not many people use these things, and that might be part of the issue of why they’re not getting a lot of attention from the government and why although some exchanges have made some statements about them that it’s not a widespread policy of banning CoinJoin transactions or anything like that. We haven’t gotten to be able to test that at the forefront yet. I think if those things become widely adopted then we’ll see how much of a big deal they really are.
Yeah. Rafael is right to point out that I am definitely not a technical expert on this, and definitely the analytics companies have an incentive to claim that they can trace every transaction on any public blockchain, including Monero, and that’s not true. I think Monero actually does have quite robust privacy. But I will also tell you that I’ve heard, not just from the analytics companies, but from some enforcement lawyers and investigators who will tell you off the record that they can easily trace coins through a CoinJoin transaction if it’s done only once. That’s not to say that you can’t get privacy on the Bitcoin blockchain, but I do think we would have seen a lot more aggressive enforcement and a lot more onerous regulation if Bitcoin was robustly private in the way that Monero is.
We see that in two ways, two ways we know that that’s true. One is we see the Department of Justice making this very aggressive statements about what they call anonymity enhancing cryptocurrencies, and they do not include Bitcoin in that set. They ban struct exchanges basically. You should be very careful about thinking through whether you can comply with your anti-money laundering compliance obligations if you’re offering these anonymity enhancing cryptocurrencies. In other words, you absolutely should not offer them, and we saw ShapeShift, for example, a delist Monero and Zcash. I think it was last week, or maybe earlier this week. The other thing we see is we do see aggressive enforcement of centralized mixing services.
For example, there was a guy, I think his last name was Harmon, who was running a mixing service called Helix that was mixing coins used on AlphaBay, a dark net market. If you’re running a centralized mixer, then you absolutely can provide privacy because essentially you’re a financial institution taking possession of other people’s Bitcoin, and then you’re mixing them up and you’re sending them out to other people, only you know who is Bitcoin belongs to who, and we have seen the US government crack down on those centralized mixing services that have not complied with the Bank Secrecy Act for the very reason that they do actually provide privacy somewhat unlike just purely on chain protocols like CoinJoin. So there is a difference there.
I do agree with Rafael that this will change as time goes on, and I do think that it’s a race to see, right? How good the privacy technology becomes versus how effective the analytics companies can be. Eventually, we will live in a world where there are private peer-to-peer transactions. I think it’s incumbent on us as lawyers and advocates to make the argument to government why that’s okay. Why? Just like they allow with paper cash, which is absolutely private, they should allow digital cash transactions and preserve privacy has an important, fundamental right even if there are some concerns from a law enforcement perspective and that’s a separate but I think extremely important part of this.
Yeah. I love hearing that. I mean, it’s fantastic points and I think cannot be overstated. I think we need action on Bitcoiners to carry this flag as well, but also policymakers and lawyers such as yourself. Well, okay. I have three things that I want to get to, but before we move off this because I think this question keeps popping into my head as we talk about privacy enhancing transactions and cash, it’s the Lightning Network. Has there been any peeps at all? Have there been any peeps at all in the legal and regulatory area about the legality of peer-to-peer transactions and privacy on the Lightning Network? Either one of you, sorry.
You can go ahead, Jake, if you have thoughts on that.
I haven’t heard anything about it. The only thing I can add on that is there’s been a concern for a while about, in just the layer one Bitcoin context, whether a miner is a money transmitter, right? In theory, a miner is processing transactions on behalf of other people. If FinCEN want it to be totally crazy, they could say miners are regulated financial institutions that have to register and report, which is insane, and FinCEN has not said that because it’s insane. In the Lightening context, there’s the same question, right? As a node operator and Lightening or money transmitter, the argument is maybe a little bit more problematic than it is for a miner because coins actually do pass through Lightning nodes, but FinCEN hasn’t taken any action on that, and they’ve had every opportunity for years to crack down on Lightening if they wanted to and they haven’t. I think that’s a good sign. But that’s all I’ve heard, and I wouldn’t swear to the fact that we shouldn’t be concerned about what may come next.
Becky just sent me an article in the chat that is titled The IRS Offers a $625,000 Bounty To Anyone Who Can Break Monero and Lightening. It looks like this is on the IRS’s radar.
Yeah. I’m guessing that this probably … I remember reading it I think earlier when it came out, but this is probably from the criminal enforcement divisions investigatory department, right? That is working on specific investigations and wants help, and is willing to pay for companies that are able to help them work on this. Although, they might want it for the broader purpose of addressing things, but not too surprising. Although I’m not an expert enough on Lightening to know how much privacy Lightening even provides to begin with compared to on-chain transactions, my understanding is that not that much.
Well, they are onion routed, the transactions are. It has the same privacy technology that Tor uses baked into the protocol itself. It is much more privacy conscious as a protocol than in the base layer is. It’s certainly attempting to provide private cash transactions, digital transactions. Like we’ve been saying here, this is a game of cat and mouse, and the coders and cypherpunks are going to produce protocols that will stay ahead hopefully of the regulators and that’s been that way for a long time, and that brings us back to the end-to-end encryption discussion. We wrap that up and put a bow on that and move on. But the DOJ has issued basically a statement that says that they are against end-to-end encryption.
Of course, their citing says that companies should embed the safety of public in system designs, enable companies to act against illegal content, and actively and effectively with no reduction to safety and facilitating the investigation, prosecution of offenses and safeguarding the vulnerable, enable law enforcement access to content in a readable and usable format. When there is lawful authorization, engage in consultation with governments and other stakeholders to facilitate legal access in a way that is substantive and genuinely influences design decisions. They’re basically saying that we should bake in back doors to end-to-end encryption. This is an open declaration of war against end-to-end encryption. Jake, you referenced the wars, the crypto wars, cryptography wars, the original crypto wars back in the ’90s. Could you talk a little bit about that, and then what your reaction is to a statement like this from the DOJ?
Yeah. Once upon a time, encrypted software was treated as basically a military weapon, right? It was only used for military purposes. It was not available to the public. When, for example, PGP, right in the early days of encryption came out and all of a sudden anyone in the world who wanted to encrypt the information could do so, and then transfer it to anywhere in the world using the internet, that became a huge concern for governments, and specifically for one enforcement. For a long time, there was an argument about whether encryption technology was legal or whether it would be a violation of export controls, right? The trade sanctions laws, to send encryption software out of the country, just like it would be to send a missile to some other country.
Basically, the resolution of what we call the crypto wars, which were these arguments in the ’90s about how encryption software will be treated, was general acceptance that, first of all, encryption couldn’t be stopped. Right? We have the example of folks who would wear tee shirts that had encryption code on them, or write a book that had encryption code in them and make First Amendment arguments about their right to freedom of speech. So there were a difficulty of government actually trying to take any action against encryption software. But also a general acceptance that for the internet to be commercially viable, you had to have end-to-end encryption, right? If you’re a business and you’re going to take a payment online, you need to have a secure channel to do that.
So government ended up leaving alone the question of encryption and moving away from trying to crack down on it. The thing is we never really won that war, right? We won one battle of that war in the early internet era, but government still has the view that privacy is only good when it is privacy among individuals and companies, but not when it is privacy from the government. The government basically wants to say it’s okay for you to have private transactions or private transmission of information as long as we, the government, can break that privacy and we can figure out what you’re doing, what you’re saying, who you’re paying, where you’re holding money. So they do want developers and companies to build back doors that the government can use into basically every product and service on earth. I think there are a lot of problems with that, but since I’m rambling on here, let me stop there and see what Rafael thinks about this.
Sure. Well, I endorse everything you just said, unequivocally. But I mean, obviously this possibility of an encryption ban, I don’t know if it’s politically viable or not. I hope not. Otherwise, well, who are we voting for? Right? If Congress authorizes something like that. But I’m guessing if something like that were to happen, then the response would be open source software that people can use that just doesn’t have back doors. Right? I’m guessing that that would continue to happen, but it would still be a terrible thing because every service that you might want to use if you’re not savvy enough to get into the open source software game is going to have these back doors and nothing you say will be private. I’m very concerned about it and I don’t have any particular solution.
I’d like to believe that raising awareness about this kind of thing can help prevent it from happening, but I’m not sure that I … I’ve never really been optimistic about political solutions. I’ve always … That’s what made me so interested in Bitcoin, is I feel like Bitcoin was a technical solution to what are political problems. And I’m happy to help, try to do whatever tiny thing I can do to move policy in the right direction, but I’m not counting on our politicians to protect us from the government in particular.
I think in terms of whether it’s politically viable, unfortunately I have to say it might be, and the reason I say that is because of a bill that recently passed. I think it passed the Senate called the EARN IT Act. If folks haven’t heard about this, it does a couple of things. One is it basically repeals section 230 of the Communications Decency Act, which is a whole other topic that we’ll have to leave for another day. But the other thing that it does is it basically allows government to require companies to build back doors into their encrypted products and services. The EARN IT Act hasn’t passed and in this lame duck session before the transition to the Biden administration, it won’t pass, but the EARN IT Act is something that we’re going to have to fight against pretty hard next year.
If that passed, I think it would be a huge attack on encryption and a really big problem for folks who believe in privacy, financial and otherwise. I think as a practical matter, these attempts to attack encryption, like Rafael said, are doomed to fail. All of this technology is open source. It can be used by anyone everywhere. I think that the mistake that government makes … There’s really a couple, one is failing to recognize the source nature of the technology and the fact that the law, even if it passes, isn’t going to be effective in practice. It’s like prohibiting sales of alcohol. Well, how well did prohibition work? How well have drug prohibition laws work? It’s similar to that. Another is failing to understand that encryption actually protects people, right?
Encryption stops us from having our identities stolen and having people fraudulently using our credit card information, and it protects us in any number of ways. That encryption is actually a net positive. Just like any technology, it’s a tool that can be used for good or bad, and it’s used for much more good than it is for bad. Lastly, that a back door can ever be effective, right? The government says that software developers and tech companies should build these perfect flawless back doors into their products that can never be compromised by any bad actors, that only the government will be able to use, without understanding that that’s just not technically possible. When we have seen back doors built into products in the past, even if it’s done at the behest of the intelligence community or law enforcement, they don’t stay secure.
I think the NSA famously had a back door that was compromised by a bad actor some years ago, and even the NSA had to admit that back doors are vulnerabilities that can be compromised. I’m hopeful that these arguments will convince our lawmakers not to go forward with an attack on encryption. But that’s just a fight that we’re going to have to battle out and win.
Unstoppable technology, and I think that’s what we’re here for. The question is how long can they hold the eventuality, the winning of these technologies against us? I would like to think, and I like your optimism, Jake, that our government, it would be amenable to those kinds of arguments. This is a First Amendment, freedom of speech, right to privacy situations, and that this is good for the citizens of this country and that we can strike a balance between those rights and individual freedom and law enforcement. I’m hopeful as well. I did want to bring up, before we wrap up the BitMEX situation, and I’d like to hear you guys break down what we saw happen with BitMEX and what you guys expect might happen. Where are we at in the legal process at this point and what’s to come? Rafael, do you want to take a first swipe at that one?
Sure. One last thing on the EARN IT Act, I just had looked it up to see which senators were sponsoring it or introducing it just because I was curious who I can be upset at, and I saw Lindsey Graham and then I also saw Diane Feinstein. These are people that don’t get along about anything, right? And call each other traitors and all kinds of other political insults, and apparently they can agree on something, which is that you shouldn’t have privacy. What an abomination! I mean, of all the things that they could get along about? They can make a deal to give people money when their businesses are shut down. That’s too difficult. But they can agree on getting rid of our privacy? I mean, it’s like a joke.
In case you needed to be disaffected by politics a little bit more than most of us already are, there you’ve got it. This very surprising to me to see. But as far as BitMEX goes, well, I’m not an expert on the CFTC issue, so I’m just going to defer to Jake on everything related to the CFTC. But one of the issues, one of the charges as far as I recall, is that they’re charged with failing to register as a money services business with FinCEN, right? This goes to what we’ve talked about earlier, right? If you’re going to be financial institution and serve customers in the United States, FinCEN wants you to register, collect information, et cetera, et cetera. Right? BitMEX historically has been Bitcoin only, which is very cool and no fiat on there.
They’ve been able to not collect information on I’m guessing the vast majority of their customers for quite a long time. I mean, I’m sure they collect email addresses and IP addresses and things like that, but not collecting the typical kinds of information. This was part of the reason that they were popular. They weren’t obviously known for their trading engine performance, right? All the freezing of the trading and the overload and all that. Those were obviously big issues. But I, as far as predicting what’s going to happen to them, can’t say I envy their position. I mean, they did take some efforts to block US users from using BitMEX, but those efforts were debatable on their effectiveness, and, right, blocking US IP addresses, you have to use a VPN and things like that.
They’re going to have a challenge, although it’s interesting that they did announce before the charges were officially brought that they were going to implement KYC. So maybe that will help them. But, well, they’ve got money, they can afford some excellent lawyers, and I cannot wait to read all the work that their lawyers do and the briefing on these issues.
Yeah. They do have I think the best lawyers you can get. So it will be interesting to see what happens. That’s a great summary. The CFTC piece that Rafael mentioned is pretty simple. The Commodity Exchange Act requires derivative exchanges to register with the CFTC if they offer swaps to US citizens. BitMEX was offering perpetual swaps. They were offering them to US citizens knowingly. They had to register with the CFTC has a futures commission merchant. By not doing that, they’ve committed a violation of the commodities laws. That’s a regulatory offense that is somewhat serious, but not nearly as serious as what they ended up getting charged with, which was violating the Bank Secrecy Act.
Because being a futures commission merchant also requires you to comply with the Bank Secrecy Act anti-money laundering compliance obligations. As we’ve been discussing for the last hour or so, the ability of the US government to surveil on sensor financial transactions is really what matters most to law enforcement. What they’re really concerned about is money laundering and terrorist financing. So they were very concerned that some of that was happening through BitMax. Ultimately, those were the more serious charges that came down against, not just BitMax as a company, but also its co-founders individually who were criminally charged, meaning they are potentially exposed to jail time for facilitating violations of the Bank Secrecy Act.
Now obviously we should say that everyone in the US is presumed innocent until they are proven guilty beyond a reasonable doubt by a jury of their peers. All of these are just the government’s allegations. We’ve only heard one side of the story. So we’re still waiting to see what the other side of the story is. But I do think that this is just more evidence about how concerned government is becoming about getting control of Bitcoin transactions and being able to head off these venues where folks are able to potentially obscure the source of funds, right? Meaning prevent the government from tracing their transactions.
I imagine there are some other offshore exchanges, frankly, who are doing the same thing. I won’t name any names, but we all know what the other offshore exchanges are that have made a show of trying to exclude US customers. But in reality, if you have a VPN, you can still get on and they are not registered with any US federal agency as they might be required to do. I think BitMax is probably the first of many that the government will go after to try to get more control over global Bitcoin markets.
The legal community was … I mean, I saw some tweets to this end anyway that a lot and several people in the legal community, at least, were surprised about the criminal allegations. Was that surprising to you, Jake?
Yes and no. It surprised me because there’s a huge difference between bringing a civil enforcement action and bringing criminal charges, right? When you turn something criminal, that is not just a sign that the facts of the particular case are serious. It is also a message that the government is sending to everyone else in the industry. I do think that this was a message to other well-known leaders of offshore exchanges that may be servicing US customers, that if they don’t cooperate with the US government, it doesn’t matter where they are in the world, right? They can be in the Seychelles or in Singapore, or they can be moving around between a bunch of different apartments in a bunch of different jurisdictions.
This game of “regulatory arbitrage” does not pass muster with US enforcement agencies. The penalty isn’t just going to be a slap on the wrist. You pay a few $100,000 and you move on. It’s you get thrown in handcuffs and you get thrown in jail to await trial and then potentially you’ll spend years in prison. It’s reminiscence in a way of Ross Ulbricht, who I think many of us in the industry believe was really penalized more harshly than he deserved to send a message to other people in the crypto industry and others who were involved in dark net markets that were using Bitcoin for potentially illicit transactions. That’s why this was so surprising.
Yeah. Yeah, one thing to add to that is … Well, Arthur meme them, right? He memed on them too hard. That was part of the impetus that is that I think I remember reading in the original complaint they actually put some meme that he posted about bribing regulators into the complaint. So they’re definitely trying to send a message and going after one of the biggest players is the way to do that. Although, it will be interesting to see what the contrast is here between what the SEC has done, right? Because the SEC went after Block.one and ended up giving them a very small settlement that they had to pay that was like pennies on the dollar compared to what they raised.
But time will tell what kind of settlement, if any, comes from the BitMEX action. One more thing just that came to mind is that earlier Jake had mentioned … I think Jake had mentioned that the government’s interest in, well, preventing money laundering, terrorist financing, right? Child trafficking, things like that. I feel like those are loaded terms that are a very good way to get people to go along with what it is you’re doing, right? It’s like, “Do you want encryption or do you hate children?” Right? Or something like that. False dichotomies. It’s either you care about stopping terrorism or you don’t, right?
I hesitate to use their language, right? I think it’s clear that the end goal is the erosion of privacy for the overwhelming majority of people who are not terrorists or sex traffickers or anything bad. For me, that’s my focus rather than on their purported goals, which are laudable to the extent that they’re really pursuing them. But just want to put that political angle in context.
Yeah. Yeah. I mean, the politics of fear should not be foreign to anybody’s understanding of how this world works, who’s watching out there this, these kinds of criminals, terrorists, child pornographers, et cetera, are leveraged to diminish individual privacy…
Yeah. They were all going 100x on BitMEX, but now we’re going to put a stop to that.
Right. Yeah. Guys, thanks so much. I really appreciate this conversation. I think it was great. Do you guys have any closing words you want to pass along to Bitcoiners regarding your work in terms of Bitcoin and law, what to expect, what we can do as Bitcoiners to help good outcomes for Bitcoin and the law?
Yeah. I guess my closing thoughts, I’ll echo something that Rafael said earlier, which is if you care about these issues, learn how to take custody of your own Bitcoin and learn how to protect your own privacy, right? The best way to signal to government that these things matter to us is to do them. Also as Rafael said, if we’re going to prepare for the worst, then you better get your Bitcoin into your own wallet while you still can while you don’t have those restrictions. I think that’s a worst case scenario, but it’s at least worth saying, if nothing else, to motivate people to learn how to do that. I would say follow me on Twitter.
I’m hoping to put out some more information as time goes on about what people can do to get involved in this fight. I do think this is something that will benefit from grassroots support. I do think there’s an opportunity for us to influence policy makers and explain to them why they should not sacrifice our individual Liberty in the name of some vague, ambiguous, theoretical advantage for law enforcement that I think ultimately won’t bear out anyway. I’m @jchervinsky on Twitter, and I’ll try to keep folks updated on that. Beyond that, that’s pretty much all I got.
Thanks so much, Jake. Rafael?
Sure. I guess my final thought, because Jake covered the essential stuff, is that … Okay. It’s a very short story, but I had an interaction with the DOJ on behalf of a crypto client, and they were asking me all this information about things that the client was doing that seemed obvious that they would be able to figure out. I asked them and I was like, “Why are you even asking me this stuff? Right? Don’t you have … Aren’t you recording all of our phone calls and reading all of our emails and watching everything that we do anyway? Don’t you have unlimited resources to be able to see what we’re doing? And why you’ve been asking me, right? If you already know the answer.” Basically, their sarcastic response was that’s exactly what we want you to think. So please continue to believe that.
If there’s some kind of silver lining or a possible, we always think about adversarially and think about what the potential downsides are, but it’s also possible that a lot of the time the government is incompetent and unorganized and doesn’t actually have a lot of the surveillance wherewithal to really get it done in a meaningful way, and that a lot of their ability to enforce laws that they feel are important is really just based on our paranoia that they’re watching, right? They don’t actually have to watch. We just have to think that they’re watching and then people will comply. I don’t know, I thought that was an interesting interaction with them. Hopefully, things are not as bad or don’t trend to be as bad as they seem like is possible, right.? There’s always … Obviously, Bitcoin succeeding this far was an unlikely outcome, or at least seemingly unlikely outcome. Who knows what other unlikely positive outcomes can be possible?
Awesome. Thanks guys. This is a fantastic way to wrap it up. Go Bitcoin, keep Bitcoining, and keep stacking, keep educating yourself, take control of your own private keys. Of course, we have Swan encourage the withdrawals and automatic withdrawals. So you can just set it up and all you do is click and approve on an email whatever your withdrawal interval’s set up, and your keys will move over into your possession. We make that as easy as possible for you to stack and to take the keys. Again, lots going on at Swan right now. You can go to swanbitcoin.com/buynow, and help us test out our buy now functionality you guys have been asking for for a long time.
In addition to stacking sets automatically regularly every day or week, you can top yourself up when you feel the need to smash buy. That’s coming soon to your Swan account. Again, lots of more coming as well. Several other big announcements coming in the next couple of weeks. We’ll keep you updated on the Twitter, @SwanBitcoin, and of course, here on this show. You can also check out Bitcoin TV at Swan’s YouTube channel. It’s youtube.com/swansignal. You’ll see the Bitcoin TV channel running 24⁄7. We’ve got the best content on the web running there in a loop. Right now I think there’s 40, 50, 60 hours, something like that. We have plans to add a lot more and it’s going to loop around. We’re going to improve it a lot.
This is just the beginning. We’re working on how to present it better, organize it better and creates the go-to source for live Bitcoin edutainment. There’s some great stuff on there. Very educational, also very entertaining. You can hang out and chat. That’s been the magical thing for me, is popping into Bitcoin TV, seeing what’s on and chatting with Bitcoiners in the live chat about it. So check that out. It’s on our YouTube. You can also just go to Bitcointv.network. It’ll take you right there. All right, that’s it for this week. See you guys next week. Take care.
Episode 8 –Andy Edstrom and Ansel Linder
Episode 9 –Rockstar Developer and Jeremy Rubin
Episode 10 – Bitcoin TINA and CK Snarks
Episode 11– Gigi and Knut Svanholm
Episode 12 –Adam Back and Preston Pysh
Episode 13 –Alex Gladstein and Matt Odell
Episode 14 –Robert Breedlove and Tuur Demeester
Episode 15 –Isaiah Jackson and Max Keiser
Episode 16 –Gigi and Udi Wertheimer
Episode 17 –Aleks Svetski and Jimmy Song
Episode 18 –Stephan Livera and Marty Bent
Episode 19 –Mark Moss and Ben Prentice
Episode 20 –Samson Mow and Parker Lewis
Episode 21–Lyn Alden and Jeff Booth
Episode 22– Robert Breedlove and Cory Klippsten
Episode 23 — Saifedean Ammous and George Gammon
Episode 24 –Jameson Lopp and Eric Martindale
Episode 25 –Preston Pysh and Andy Edstrom
Episode 26 –Lyn Alden and Nic Carter
Episode 27 — Erik Townsend and Yan Pritzker
Episode 28 — Max Keiser and Tone Vays
Episode 29 –Preston Pysh and Andy Edstrom
Episode 30–Raoul Pal and Vijay Boyapati
Episode 31–Dan Tapiero and Dan Matuszewski
Episode 32–Robert Breedlove and Parker Lewis
Episode 33– Danielle DiMartino Booth and Michael Saylor
Episode 34– Jeff Deist and Stephan Livera
Episode 35–Will Reeves and Yan Pritzker
Episode 36– Alex Gladstein and Marty Bent
Episode 37– Brandon Quittem and Robert Breedlove