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Paypal's Green Mining Initiative Makes Zero Sense

Paypal's Green Mining Initiative Makes Zero Sense

Last week Paypal released a whitepaper in partnership with Energy Web and DMG Blockchain Solutions, describing a “Green Mining Initiative” intended to redirect fees from participating users specifically to certified miners powering their operations with renewable energy. I can’t say I’m surprised by this honestly, mining has at this point become very normalized in terms of its use to further renewable energy or climate goals. Mining is actually very suited to this task given its nature, miners are mercenaries looking for the cheapest energy possible to devote towards solving the next block. If you have stranded power, or excess power, they will take it.

The overall architecture of this system though is beyond the territory of Rube Goldberg. I am kind of amazed that this is the level of technical understanding and sophistication that a major company like Paypal has on tap, especially in their Blockchain Research Group specifically focusing on this space. The entire thing is inefficient, absurd, and some of the end goals or possibilities they discuss are not built upon sound economic incentives.

The Core Design

The entire gist of the design is to ensure that when a compliant user broadcasts a transaction to the network, only a certified green miner can collect the associated transaction fee. The problem with this is that mining fees from a transaction are collectible from any miner who includes them in a block, not just certified ones. A mechanism is required to guarantee only certain miners can collect a few.

The first thing you have to do is identify which miners you want to be capable of claiming the restricted fee. They propose utilizing a system called “Green Proofs for Bitcoin” offered by Energy Web. The proofs are certifications from the organization that a miners energy mix or impact on the grid meets some threshold of renewable energy use or positive impact on the power grid. In the certification process each miner can register a public key, creating a list of each certified miners public key.

This key certification is at the root of what enables ensuring only the correct miners can claim a fee. Compliant users’ wallets can query or be provided with a list of all certified miners bitcoin addresses, and from there have the information needed to create a special transaction that only they can claim the fee for. The trick is a multisig output. There are no hard limits of how many keys need to sign for a multisig address, so compliant users can include the fee to certified miners in a special output with a 1-of-n multisig script that any certified miner can spend. A minimal fee at the bottom of the mempool feerate range is also included traditionally just to ensure that it propagates across the network.

The last piece of the puzzle is actually claiming the fee. If a certified miner was to mine a block including a green transaction, and not also include a transaction spending the fee output to themselves, then any certified miner could claim the fee output in the next block they mine. There, for each green transaction a certified miner includes in their block, they must include a corresponding transaction sending the fee output to an address only they hold a key for.

Special wallets can craft transactions with fee outputs only claimable by certified miners, and these users can preferentially direct their fees towards miners certified as using renewable energy or creating some other positive impact on the grid.

Full of holes and incomplete thinking

Firstly, the general idea of requiring miners to include a second transaction of their own is an incredibly inefficient design, which they do acknowledge in the paper. What they don’t acknowledge is the economic realities this implies for transactions’ feerates.

A Bitcoin transaction pays fees based on the amount of space it takes up in terms of data. By introducing the need for miners to take up blockspace creating a secondary transaction collecting this “green fee” they are economically speaking increasing the size of the green transaction itself. This is very similar in practice to Child-Pays-For-Parent from an economic perspective.

With CPFP, a transaction spending an output from an unconfirmed transaction pays an abnormally high fee. This by averaging the fee the second transaction pays across both itself and the first transaction, which must be confirmed before the second one can be, increases the feerate of the first transaction. This green fee collection mechanism is the same dynamic, but in reverse.

By requiring the miners to craft a second transaction to claim the fee, assuming the fee output pays an average feerate, the net fees the miner collects per byte of data is actually lowered. The blockspace required to collect it could have been used to include another fee paying transaction. So in reality, the fee a compliant user includes for certified miners must also pay for the miner’s claim transaction, in effect meaning compliant users have to pay more absolute fees to achieve a specific fee rate. Why would users do this?

In a vacuum this dynamic guarantees that either compliant users have to overpay, or certified miners wind up actually making less revenue all things equal. The former is irrational from a consumer point of view, and the latter completely fails to achieve the goal of rewarding miners using renewables extra revenue.

A second glaring issue, and an amazing one, is their thinking of how to structure the 1-of-n multisig script. With traditional pre-Taproot multisig, each individual key in the multisig must be present in the script. This presents a problem. The size of the green fee output grows linearly for each miner who has a key in the multisig.

The plan laid out in the paper describes breaking miners up into subgroups, and rotating between which group you pay fees to each time you transact. I.e. if there are 21 miners, split them up into 3 groups of 7, moving to the next group to send the fees to each time you transact. This would create a highly irregular distribution of fees between all the certified miners, as the rate of transactions amongst compliant users and rate of rotation between them is not something that can be prescribed or made regular. Not to mention, it seemingly shows a complete lack of awareness of Schnorr based multisig schemes like FROST.

Schnorr based multisig scripts use aggregate keys, meaning no matter how many member keys are involved, only a single public key is needed for the script, and only a single signature is required. This would completely address the issue of multisig script size, and do away with the requirement for the clunk breaking up of certified miners into subgroups.

They also make no mention of more efficient mechanisms for actually collecting the fee. A single secondary transaction for each green transaction is mind blowingly inefficient. An very obvious mechanism to be more efficient with use of blockspace would be to sweep all of the green transaction fee outputs in a single transaction. This would require only a single transaction output to aggregate all of the fees into a single UTXO, rather than a discrete output for each individual fee, and also creating the need to combine them with yet another transaction later.

They finally go on to discuss the potential of a centralized out of band mechanism directly to certified miners, but bring up the centralization, introduction of trust, and complexity of implementing direct communication to each individual miner as reasons for designing the distributed protocol described above.

The Market Alright Does This

At the end of the day, the technical inefficiencies and lack of grasping blatantly obvious solutions (at least partially) to them, aren’t even the most confounding part of this to me. It’s attempting to insert incentive distorting dynamics into the application layer of the protocol to address the concern over renewable energy in the first place. Why? The market literally handles this incentive all by itself.

https://en.wikipedia.org/wiki/File:Electricity_costs_in_dollars_according_to_data_from_Lazard.png

Renewable energy is the cheapest energy even when taking into account the cost of construction and operation of energy production capacity. Miners chief concern is finding the lowest priced energy they possibly can. Why is Paypal trying to interject weird systems giving users a distortionary mechanism to restrict fees only to certain miners, and overall introduce a distortionary market mechanism into this picture? The market already does what you want. Renewable energy is cheap, build more of it and miners will come and buy it, bringing revenue to finance the operation (especially when it is initially disconnected from the grid and has no other consumers).

The entire dynamic of fees in Bitcoin is that it is a completely open market, where any miner can compete to collect fees from any transaction by including them in their own blocks. This entire dynamic is built to incentivize maximal competition between miners to provide security and finality to users of the network. Trying to introduce weird distortions like this proposal into the system is a destabilizing factor in the balance of competition and network security, and is completely redundant given the market realities of the mining ecosystem.

Do you want to see Bitcoin mining be a positive factor in incentivizing and helping expand renewable energy production? Great! It already does that, no changes needed. It does not need Rube Goldberg machinations slapped on top to accomplish that goal, the inherent market based mechanisms of competition between miners already does that.

I really don’t understand what Paypal, DMG, and Energy Web are thinking here. 


via bitcoinmagazine.com
Samourai Wallet: Breaking Down Dangerous Precedents

Samourai Wallet: Breaking Down Dangerous Precedents

On Wednesday, the founders of the Bitcoin privacy wallet Samourai Wallet were arrested and charged on behalf of the US Government. The indictment could set dangerous precedents beyond Bitcoin privacy services.

“If your government is worried about their own citizens controlling their money, the most important question you have to ask is ‘what the hell is wrong with my government’”

– Andreas Antonopolous

Last wednesday, Samourai Wallet founders Keonne Rodriguez and William Hill were arrested and charged with conspiracy to money laundering and conspiracy to operate an unlicensed money service business in the Southern District Court of New York. The indictment alleges that Samourai Wallet “facilitated more than $100 Million in money laundering transactions from illegal dark web markets”.

The definition of a non-custodial wallet as a money service business and the consequent indictment of the wallet’s maintainers can set dangerous precedents for the wider Bitcoin space and may go as far as affecting the freedom of the internet, essentially endangering all individuals, organizations and technologies involved in the transfer of financial transactions without exercising control over funds.

Can a non-custodial wallet be a money service business?

FinCEN’s 2019 guidance on persons administering, exchanging, or using virtual currencies, define a money transmitter as a “person that provides money transmission services,” or “any other person engaged in the transfer of funds.” As the guidance states, “a transmitter initiates a transaction that the money transmitter actually executes.”

The guidance further states that “the term “money transmission services” is defined to mean the acceptance of currency, funds, or other value that substitutes for currency from one person and

the transmission of currency, funds, or other value that substitutes for currency to another location or person by any means.”

As a non-custodial Bitcoin wallet, Samourai Wallet’s operators do not take custody of user funds and therefore are technically incapable to “accept” deposits or “execute” the transmission of funds, contrarily to what is alleged by prosecutors, stating that "Samourai engaged in the unlicensed receipt

and transmission of funds, including funds deposited into a Samourai wallet by an undercover law enforcement agent located in the Southern District of New York."

However, technically speaking, the agent deposited funds into an application running locally on his device, with no engagement from Samourai operators – a circumstance correctly noted by prosecutors throughout the indictment, stating that “the private keys for these cryptocurrency addresses are stored in each user's individual cell phone”, that “these private keys are not shared with Samourai employees,” and that "the Samourai software on the user's cellphone will broadcast a transaction to the blockchain."

The indictment yet alleges that Samourai Wallet “facilitates transactions between Samourai users” – a claim that seems blatantly incorrect in the face of the fact that coinjoin transactions do not facilitate transactions between users at all, but rather create a shared transaction in which every user spends their own funds to themselves.

The indictment further repeatedly alleges that Samourai creates "new addresses" used during the transactions, and that “The Samourai server is responsible” for broadcasting transactions – claims which, too, are technically incorrect as transactions are created solely on the users device and Samourai only broadcasts transactions on behalf of users if users choose to broadcast their transactions via Samourai’s node. For anyone running their own node with Samourai Wallet, known as “Dojo”, transactions are broadcast by users themselves.

Numbers provided by the node provider Ronin Dojo suggest that up to 85% of Whirlpool users run their own Dojo. It is questionable whether organized criminals would rely on nodes provided by Samourai Wallet as its operators would effectively be enabled to deanonymize transactions by gaining knowledge of users' extended publickeys, a design choice often criticized in Samourai Wallet’s architecture. Notably, the indictment makes no mention of “Dojo” at all.

DoJ Challenges FinCEN Guidelines

The indictment against Samourai appears to suggest that the DoJ does not believe FinCEN guidelines apply as reflected in the language used to describe Samourai's services, in which prosecutors note the broadcasting of transactions, the operation of a centralized server, and the subsequent collection of fees from the services offered:

"The Samourai server is responsible for broadcasting the Ricochet transactions to the BTC network [...] From Whirlpool and Ricochet, RODRIGUEZ and HILL earned at least $4 million in fees"

The DoJ's arguments appear more in line with recent recommendations issued by the financial action task force. FATF, an intergovernmental body established by the G7 in 1989 to combat money laundering and terrorist financing risks, is not a regulatory body, but the task force’s recommendations are known to form the basis of informing AML/CFT regulations around the world.

In recommendations issued in 2021, FATF expands the definition of virtual asset service providers as “decentralized exchanges or platforms” which “have a central party with some measure of involvement or control," such as developing "user interfaces for accounts holding an administrative "key"" or "collecting fees.”

By the logic put forward by FATF, it appears that the development of any individual, organization or technology interfacing with financial transactions could require a money service business license. Notably, a new AML package adopted by the European Parliament last week aimed at updating current AML regulations in accordance with FATF recommendations, specifically exempted self-custodial services.

Similar attempts to circumvent FinCEN guidelines are currently being made on the Tornado Cash case. In an opposition issued on April 26th, prosecutors argue that the definition of money transmitting "does not require the money transmitter to have “control” of the funds being transferred," highlighting that Section 1960 of US Code, a codification of permanent federal laws, extends the definition of money transmitting to “transferring funds on behalf of the public by any and all means.”

As interpreted by the department of justice, AT&T would require a money service business license to allow customers access to their PayPal, an ISP would need a money service business license to allow users to access online banking services, a postman would require a money service business license to deliver cash in mail, a grocer would need a money service business license to hand out change, and Telegram, WhatsApp, Signal and X (formerly Twitter) would require a money service business license if users utilize the platform to share PSBTs or lightning invoices – subsequently deeming all such services to require full know your customer verification.

Can the Bitcoin Network be KYCed?

The indictment has sent ripples through the Bitcoin ecosystem, leaving anyone involved in the broadcasting of Bitcoin transactions in uncertainty, including bitcoin miners and node operators. The non-custodial Lightning wallet Phoenix has since announced the suspending operations in the US. The privacy-first Bitcoin wallet Wasabi Wallet has banned US users from accessing its services and software.

Reading the indictment, it appears as though everything we knew about the regulatory aspects of money transmission may have been misapplied, as the indictment appears to go as far as to attempt the criminalization of self-spending. As the indictment reads, self-spends, as evident in coinjoins and Samourai's Ricochet, "further obscure ownership of the funds.” But any Bitcoin wallet allows users to generate self-spends and essentially circumvent blockchain surveillance mechanisms and censorship, further muddying regulatory waters.

The foundations to introduce KYC to the Bitcoin network have been researched as early as 2016 with the MIT ChainAnchor project, which explored the introduction of identities and permission groups to blockchains, preventing non-registered users from having transactions mined in blocks.

With increasing miner centralization, with around 47% of hashrate’s mining rewards custodied by a single custodian, including the pools of AntPool, F2Pool, Binance Pool, Braiins, btcom, SECPOOL, and Poolin, plans to KYC the Bitcoin network may not seem too far fetched. In 2023, F2Pool already began censoring transactions in line with the OFAC sanctions list.

Since the indictment of the Samourai founders, the FBI has issued a PSA concerning cryptocurrency money service businesses, alerting the public to avoid services which do not require know your customer information.

If the non-custodial operation of services is ruled to classify as money transmission, the doors could be open to KYCing any service operating communication protocols, from Nostr to WiFi hotspots and telecommunication providers. If spun ad absurdum, it could even be argued to require the registration of KYC for the use of highways or the purchase of briefcases.

Plans to KYC the internet have been around since as early as 2014, when the US Government attempted to introduce a "drivers license for the internet," similar to the planned introduction of digital identities around the world.

It should be noted that the treatment of Samourai founders, who are currently serving pre-trial detention, stands in no comparison to the handling of financial crime allegations around the world. Since 2000, traditional financial institutions, such as UBS, JP Morgan, and Bank of America, have been fined over $380 Billion. The argument that traditional banks are primarily used for legal transactions can also be applied to Samourai Wallet, as the indictment reportedly only alleges the transmission of illicit funds of 3.6% of Samourai’s total transaction volume, leaving 96.4% of legitimate usage.

The Samourai case has been assigned to judge Richard M. Berman, who previously presided over the the Jeffrey Epstein case. In 2005, Berman ruled that random police searches of riders bags on the New York City subway did not violate the U.S. constitution. 

This is a guest post by L0la L33tz. Opinions expressed are entirely their own and do not necessarily reflect those of BTC Inc or Bitcoin Magazine.


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Mysterious 2010 Bitcoin Whale Launches Bitcoin-Only Market-Making Certificate

Mysterious 2010 Bitcoin Whale Launches Bitcoin-Only Market-Making Certificate

The below is an excerpt from a recent edition of Bitcoin Magazine Pro, Bitcoin Magazine's premium markets newsletter. To be among the first to receive these insights and other on-chain bitcoin market analysis straight to your inbox, subscribe now.

Introduction:

The Bitcoin Volatility Premium AMC, an innovative investment product, has quickly become the largest actively managed bitcoin-only financial product in Europe and the second largest globally. Despite this achievement, to date this bitcoin-only AMC has flown under the radar and has received no media coverage to date until now. What makes this investment product offering particularly interesting is its dramatic rise was due to the seed investment of $50 million to launch from an enigmatic early Bitcoin miner from 2010. The product is designed to curb Bitcoin's volatile pricing, fostering its adoption as a reliable medium of exchange.

What is an AMC?

AMC stands for Actively Managed Certificate. It is a type of structured security that is popular in Europe. Jurisdictions such as Luxembourg and Jersey allow asset managers to create these certificates in order to raise capital from investors. Certificates provide a “wrapper” for an investment strategy, or specific underlying assets. The certificate is sold to investors and the capital is used to implement the strategy.

Who is the Mysterious Whale?

In response to inquiries about the identity of the Bitcoin Whale behind the new Bitcoin Volatility Premium AMC, Zeltner & Co. confirmed that the seed investor is indeed an early Bitcoin miner who has been involved in Bitcoin since 2010. However, respecting the investor's request to preserve privacy and avoid public scrutiny, Zeltner & Co. declined to reveal any further details about their identity. The motives behind such a significant move by an individual with substantial Bitcoin holdings are particularly intriguing. The creation of this AMC, aimed at stabilizing Bitcoin's price, showcases a strategic approach to managing digital assets. By personally allocating their holdings to develop this investment product, the Bitcoin Whale not only addresses the issue of Bitcoin’s volatility but also enhances its viability as a stable medium of exchange. This AMC stands out as a unique market-making instrument that not only seeks to manage risk but also differentiates itself through its operational approach, targeting a more stable and predictable market for Bitcoin.

Why is this AMC Relevant?

The Bitcoin Volatility Premium AMC, has already become the largest actively managed bitcoin-only financial product in Europe and the second largest globally after the Purpose Investments Bitcoin Yield ETF (BTCY), with over $109 million CAD ($80.750 U.S.). There are several large Bitcoin ETFs that actively manage futures positions, such as the ProShares Bitcoin Strategy ETF (BITO), with over $2.82 billion in assets under management; however, these are not actively managed funds in the traditional sense. Instead of trying to outperform or optimize the risk/return of a direct investment in bitcoin, futures ETFs aim to track the price of bitcoin 1:1.

The difference between an ETF and an AMC is that ETFs are passively managed. That means that they track the underlying asset. Whereas AMCs are actively managed, which means they try to outperform the underlying assets on either an absolute return or a risk-adjusted return.

Figure 1: Largest Active Bitcoin-Only Funds and Structured Products

Source: Bitcoin Magazine Pro

How is its Investment Strategy Unique?

The certificate invests algorithmically in bitcoin and U.S. dollars, aiming to collect a volatility premium while optimizing the risk-return profile directly by investing in bitcoin. The strategy provides liquidity to the BTC/USD spot market with market making on leading exchanges such as Kraken. This leads to small gains, which can accumulate between 2% and 6% per annum, depending on volatility. The volatility premium is generated when the market moves from filling the buy orders generated by the algorithm to filling the sell orders, and vice versa. The algorithm buys low and sells high at each dip or peak, respectively.

Figure 2: Risk Profile of Bitcoin Versus Zeltner & Co. Bitcoin Volatility Premium

Source: Zeltner & Co.

Similar to ETFs, as more investors invest in certificates of the Bitcoin Volatility Premium AMC, the certificate must purchase more bitcoin, therefore increasing the demand for bitcoin, which already outpaces the newly created daily supply by several factors. The market making targets an allocation of 70% Bitcoin and 30% U.S. dollars, meaning that the strategy currently owns over 540 Bitcoin.

Market Impact and Future Prospects:

The goal of the Bitcoin Volatility Premium AMC is to mitigate the price fluctuations of Bitcoin, making it more stable and functional as a medium of exchange.

Dr. Demelza Hays, a portfolio manager at Zeltner & Co., shared insights with Bitcoin Magazine Pro:

"Bitcoin's potential to become a global medium of exchange and money hinges significantly on achieving stable purchasing power. Currently, the volatility inherent in Bitcoin's price poses a barrier to its widespread adoption for everyday transactions. However, if Bitcoin were to stabilize in value, it could emerge as a viable alternative to traditional fiat currencies, offering benefits such as decentralization, security, and lower transaction costs on Bitcoin scaling solutions such as Liquid, AQUA, and the Lightning Network."

By becoming the largest actively managed bitcoin-only financial product in Europe and a major player globally, the AMC leverages an algorithmic strategy to invest in Bitcoin and U.S. dollars. This strategy aims to profit from market volatility, which in turn influences Bitcoin's demand and price dynamics.

Swiss Family Office Involvement:

The strategy is managed by the prestigious family office Zeltner & Co., based in Zurich, Switzerland. Founded by Thomas Zeltner, Zeltner & Co. is continuing the legacy of Thomas’s father, the late former president of UBS' wealth management, Jürg Zeltner. Zeltner & Co., renowned for its discretion and expertise in wealth management, has lent credibility to this venture, solidifying confidence in the strategy's legitimacy and potential for success.

Regulatory and Geographic Advantage:

Choosing Zurich, Switzerland for its headquarters, the AMC benefits from the region's favorable regulatory environment and its reputation as a global finance and innovation hub. This strategic location enhances the security and appeal of the Bitcoin Volatility Premium AMC to investors seeking to diversify into digital assets.

Conclusion:

The launch of the Bitcoin Volatility Premium AMC comes at a time of heightened interest, with bitcoin recently surpassing all-time highs and capturing the attention of institutional investors and mainstream media alike. As the market continues to mature and attract greater institutional participation, the emergence of innovative investment vehicles such as this certificate highlights the evolving nature of digital asset management.


via bitcoinmagazine.com
First Bitcoin ETF to launch in Australia in 2024: Bloomberg

First Bitcoin ETF to launch in Australia in 2024: Bloomberg

The Australian Securities Exchange (ASX), which accounts for the majority of trading volume in Australia, is expected to approve the country's first spot bitcoin ETFs on ASX before the end of 2024, according to a recent Bloomberg report citing anonymous sources familiar with the matter.

Two entities, Cosmos Asset Management and 3iQ, have already applied for spot bitcoin ETFs with the ASX, while VanEck Australia is working towards submitting its application, as per Bloomberg. 

Earlier this month, Australia-based asset manager Monochrome also applied for a spot bitcoin ETF with rival exchange Cboe Australia.

The potential launch follows major spot bitcoin ETF approvals in the US and Hong Kong. In January, the SEC approved several US spot bitcoin ETFs, which attracted over $200 billion in volume within just three months. 

Meanwhile, Hong Kong's first spot bitcoin ETF is set to begin trading tomorrow after receiving regulatory approval last week.

The success of spot bitcoin ETFs in these major financial hubs has prompted Australia to follow suit. With the ASX expected to approve spot bitcoin ETFs by year's end, Australia is positioning itself to benefit from surging demand.

Click the image to learn more.

This is a major milestone for Bitcoin adoption in Australia and reflects the growing acceptance of Bitcoin's investment merits. As more countries approve spot Bitcoin ETFs in the wake of the US, it further validates Bitcoin and could compel additional uptake worldwide.


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Shadow Boxing: Comments On Proof-Of-Work Centralization Hysteria

Shadow Boxing: Comments On Proof-Of-Work Centralization Hysteria

The always-relevant Marty Bent had Spiral developer Matt Corallo on his podcast this week to address the freaks about urgent Bitcoin mining matters.

To bring everyone up to speed, the concerns stem from recent sleuthing of the blockchain which revealed that some pools have been getting perhaps a little too cozy.

How do we know this? Well, everyone’s favorite snoop mononaut recently pointed out that an unusual percentage of Bitcoin’s mining reward was being consolidated under the control of a single custodian.

How bad is it? Well about 47% of the hashrate, on a good day. Yeah, pretty bad.

Now why in Satoshi’s name would they do such a thing, you ask?

C.R.E.A.M.

To begin with, have you looked at the hashrate chart lately anon? You practically can’t tell it apart from the US debt hockey stick. Backed by hardware advancement, public balance sheets, and increasing forays into cheap energy sources, Bitcoin mining has become an arms race. Since the Chinese mining ban of 2021, the network’s hashrate has more than quintupled.

The effects this has had on miners’ margins are self-explanatory. Everyone is squeezing each other out. The recent bear market saw a bunch of consolidation, particularly on the Western front. At the pool level, Foundry has been the biggest benefactor with nearly 25% of the current hashrate, down from 35% last year.

The reason they attained such dominance so quickly is something Bitcoiners are well acquainted with: volatility. In this case, it’s more often referred to as variance. Others simply call it luck.

Luck, under the conditions described above, can make or break your business. It’s the reason pools exist in the first place. Proof-of-work is a random process and randomness is the bane of cash flow. By combining your hashrate with others, you improve your odds and, perhaps, manage a more reliable revenue stream.

This is important because when your bills come due every month, your utility provider doesn’t care about your misfortunes. The tighter the margins, the more vulnerable you are. In today’s competitive environment, it’s a matter of survival.

What does any of this have to do with Foundry?

Well, it turns out another way to smooth over miners’ income is to adjust your pool’s payout scheme and completely remove variance from the equation. How? Simply pay them for their work regardless of how often you might mine a block. A process referred to as FPPS (Full Pay Per Share).

If that sounds expensive to you that’s because it is. The pool effectively has to front every payment out of pocket and hope they can pay themselves back with the blocks they eventually mine. If you hit a bad streak and your balance sheet isn’t strong enough to absorb the lack of revenue, you’re Sam Bankman Fried.

Enter Foundry. Through a combination of uncanny timing, business savvy, and a DCG-sized war chest, they’ve created a financial moat around their pool operations that makes it very hard for smaller players to come in and compete.

Of course, it’s slightly more complex in practice, but that’s pretty much the gist of it.

Back to our little posse of pools and the mysterious custodian. Have you figured it out yet?

The same game is playing out on the other side of the pond. It’s very likely that the emergence of Foundry as a major player exacerbated the dynamics laid out above and forced smaller pools to capitulate.

The execution appears to be slightly different but it’s essentially the same model. We can validate that several pools now share the exact same block templates. This matches with reports that Antpool is offering white-labeling services.

That’s right — proxy mining is, apparently, a business model.

On top of this, the aggregation of coinbase outputs suggests that an even larger percentage of the hashrate seems to be financing their operations through the same provider.

To put it another way: a single entity writes the checks for almost half of the network’s hashrate.

Dollar dollar bill, y'all.

If what you say is true. The Shaolin and the Wu-Tang could be dangerous

As you would expect, this situation led some talking heads to raise some alarming questions about mining centralization. For context, this is not the first time mining gets awkwardly consolidated.

As I wrote in this week’s Weekly Re-Org, time is a flat circle. The Proof-Of-Work centralization Manbearpig comes out of his cave every cycle. It’s a seasonal happening.

What’s rather unusual is for one of the most senior developers in this space to go full DEFCON 1.

I will leave it to more serious journalistic outlets like the Bitcoin Bugle to speculate on the strange coincidences between this outburst and the fact that Matt’s employer has mining ambitions.

Look, it’s not pretty. I think we can all agree that such a significant portion of the hashrate being at the mercy of a handful of bankers is gross. Bitcoin’s security relies on miners aligning with their financial incentives. If that is the outcome, something’s wrong and censorship resistance is at risk.

The reaction, though, is unwarranted. Bitcoin mining has followed noticeable growth patterns throughout its history and this particular one is not different. It is a market driven by economics and not by code. Inefficiencies arise at every stage and are subsequently dampened as the industry progresses.

I understand every man who owns a keyboard looks at everything like a bug but the current reality does not fit this framing.

Everyone applauds the work that has gone into StratumV2 to optimize the mining interface but it’s not an answer to the current predicament. Even if they can be custom, transaction templates are still permissioned. The pools can always reject any transaction they deem haram. Patronizing operators for showing little interest in the solution and miners for not demanding it is verging on hubris.

Custom transaction selection cannot be relied upon for censorship resistance. Only the market can realistically address this problem and it just so happens that Bitcoin is explicitly designed to be robust to mining majorities. Using fees, users create a financial incentive for competing miners to drive enough hashrate behind a transaction for it to be mined. Curiously, this implies that, in a perfect world, every miner is mining off of the same template: the most profitable one.

In practice, things are a little more shall we say… spooky. As uncomfortable as this may be, censorship is inevitable. Following this week’s events, the writing is on the wall and while a lot of grief is given to Chinese miners, it seems most likely to come from our side.

By far the most disappointing aspect of this agitation is the endorsement of a change to the Proof-Of-Work algorithm. The threat being levied against us by the State as we currently speak makes the rhetoric around firing miners especially aggravating. It’s tone-deaf and shows a complete lack of discernment about the challenges before us. Divide and conquer, anyone?

To make matters worse, we know that throwing the baby out with the bath water is a recipe for disaster. Changing the algorithm. “Firing the miners.” It achieves nothing.

Again, the technocratic mind is blind to any issue not resolved by a pull request.

By going scorched earth, you ensure that only the most well-capitalized participants will ever participate in your game. Hashrate can be wiped away at the stroke of a key but technical prowess and large enough bags can endure nuclear winter. The ASIC manufacturer market likely resets to a single player, one who already specializes in custom algorithms. Monopolies relish nothing more than good old interventionism to help shed the competition.

From a consensus perspective, the idea is so absurd it flies in the face of the entire premise of the system.

If Bitcoin requires social coordination to throttle the whims of the market and fiddle with its incentives, it is a failed project. Proof-of-work is an economic design, not a technical contraption you can fix with code.

Wu-Tang Financial

Well, I can only humbly propose we begin to consider addressing market dynamics with market solutions.

To the best of my understanding, the underlying issue is related to Bitcoin’s capital markets. Resourceful actors who quickly caught on to the issue faced by smaller mining operations have filled a hole in the market and left no room for anyone else. Economies of scale and the perceived risk associated with mining have kept competitors at bay.

There is an opportunity here for a handful of ambitious players to bring balance to this market and allow pools to source capital without bending the knee to larger competitors. This won’t happen overnight. Relationships must be built and the general information asymmetry that has plagued this market must be addressed.

This is why we must stop burning bridges.

Of course, technical improvements can also be made to mitigate the underlying variance problems but they cannot remedy the growing pains of an immature market.

Bitcoin, in every respect, is going through its teenage years. No one wants to be told what to do and pushing one way will inevitably lead to resistance. Sure, there might be no rhyme or reason to what some participants decide to do but it’s not anyone’s place to decide for them.

This too shall pass. Until then…

Wu‐Tang Clan Ain’t Nuthing ta F’ Wit


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Top 10 Tips for Every Bitcoin Multisig Beginner

Top 10 Tips for Every Bitcoin Multisig Beginner

Originally published on Unchained.com.

Unchained is the official US Collaborative Custody partner of Bitcoin Magazine and an integral sponsor of related content published through Bitcoin Magazine. For more information on services offered, custody products, and the relationship between Unchained and Bitcoin Magazine, please visit our website

As technical director on the Concierge team at Unchained, I’ve fielded countless client questions about bitcoin multisig. If you’re just beginning to understand the benefits of multisig and how it works in a collaborative custody context, I hope these ten tips will address some of your questions.

Bitcoin doesn’t live on your device

The phrase hardware wallet might make it seem like your bitcoin live inside the wallet itself, but that’s not the case—bitcoin is never in your device at all. In actuality, your wallet generates and stores your keys only. Your wallet also makes accessing the keys user-friendly by either plugging your device into a general-purpose computer or sharing information with your computer via a microSD card.

So where does bitcoin live, then? The bitcoin blockchain is a ledger that keeps track of every transaction that has ever occurred and the balances of every address on the network. Instead of storing your bitcoin, your hardware wallet protects and stores the keys used to unlock—or spend—bitcoin from those addresses.

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You can restore your seed phrase to another hardware wallet

When you set up a bitcoin hardware wallet that respects best current practices, you should be prompted to back up your wallet using 12 or 24 words, typically on a slip of paper that the manufacturer suggests you protect in case something happens to your wallet. These 12 or 24 words are your seed phrase, as established in Bitcoin Improvement Proposal 39, or BIP39.

Your seed phrase is like the “key to the castle,” it contains everything you need to recover and use a key to all of the addresses protected by the seed phrase.

The nice thing about BIP39 seed phrases is that they are interoperable among hardware wallets that support the standard, which means you can recover your bitcoin wallet backup (seed phrase) to another brand of hardware wallet. If you initially set up your bitcoin wallet on a Trezor and want to move to a Coldcard, it’s as simple as importing those 12 or 24 words.

Read more: How to replace or upgrade a bitcoin hardware wallet

You don’t need your hardware wallet with you to receive

With physical cash, you have to be physically present to trustlessly and securely transact with another party. Bitcoin fixes this for the digital world. If you want to receive bitcoin but don’t have your hardware wallet at hand, you can still have a payment sent to the appropriate address.

As mentioned above, bitcoin does not live on your hardware wallet; it lives on the bitcoin blockchain. For that reason, as long as you or someone else sends bitcoin to an address that you hold the private keys to control, you’ll always be able to move those funds regardless of whether you have physical access to your device. If bitcoin is sent to an address you know you control, it will arrive perfectly fine in the background without your involvement.

What this means for you: If you create a multisig wallet and store your hardware wallets or seed phrases in secure locations, you don’t need to have physical access to them to deposit funds.

A device used as a key in multisig can still be used as a singlesig wallet

Multisig involves constructing a multisig wallet using the public keys of multiple devices, each of which could also serve as a standalone singlesig wallet without any issues. When you create a multisig wallet following the emerging standard processes, the preexisting singlesig counterparts have no idea the multisig wallet exists.

You could think of it as a group email address that forwards to multiple individual email addresses.

This means that, if you wanted, you could store smaller amounts of bitcoin on a singlesig wallet—all while keeping your primary wealth in a multisig wallet constructed using that device as one of the keys.

Confirm your multisig deposit address

Bitcoin transactions are completely irreversible, which means if you send your bitcoin to the wrong address, it can be lost permanently. Thankfully, you can use hardware wallets to check your multisig bitcoin address on the device before sending funds.

Checking your address on your device confirms three things:

  1. that the address was built correctly (i.e. that it’s 2-of-3 multisig, for example, and not 2-of-5 where an attacker has added two keys and actually controls the funds)
  2. that the computer you’re working on isn’t compromised with malware that finds and replaces bitcoin addresses with an attacker’s address, and
  3. that your device holds a key to the address.

Checking the address on your device should be done before sending meaningful amounts of funds to any address, whether singlesig or multisig. As of this writing, Trezor and Coldcard support checking multisig deposit addresses in the Unchained platform.

Read more: How do I verify the receiving/deposit address on my hardware wallet?

You don’t need your devices physically together to sign

With multisig, you don’t need to have all your keys in the same place at the same time to spend bitcoin. That means you can sign a transaction in Austin with one key and sign a day later in Dallas with the other. The transaction can only be broadcast after all the necessary signatures have been collected (two in a 2-of-3 multisig scheme, for example).

This is a significant advantage over other bitcoin custody models like Shamir’s Secret Sharing Scheme, which allows you to distribute control over your bitcoin private key by splitting it into multiple parts (secrets), but requires all parts to be present at the same time to recompile a single key and author a transaction.

You can make a mistake in multisig and still recover your funds

In all bitcoin multisig setups where m (the number of keys required to sign) is less than n (the total number of keys in the quorum), you are protected from single points of failure and can still recover your funds in the case that one or more critical items are lost, stolen or otherwise compromised.

There are scenarios in 2-of-3 multisig (with a collaborative custody partner like Unchained holding the third key), where as many as three items could be compromised before it becomes impossible to recover your funds.

Some ideal places to store bitcoin wallets and seed phrase backups

Even though fault-tolerance in multisig provides peace of mind, all of these scenarios should still be protected against at all costs by following seed phrase and hardware wallet storage best practices, and you should always regain full control as soon as possible in the event that any of your critical items are lost or compromised. And that leads us to number eight…

Read more: The ultimate guide to storing your bitcoin seed phrase backups

You can replace a key in your multisig setup if needed

When using bitcoin multisig, if you ever lose a wallet or misplace a seed phrase, it’s important to replace this key in your multisig m-of-n scheme. You can do this with any of the popular multisig wallets.

Even if a single compromised key does not alone jeopardize your funds in most common multisig m-of-n schemes, replacing a compromised key will ensure that you regain complete control over your funds and eliminate the possibility that the key could ever be used against you in the future.

In a collaborative custody model like the one we use here at Unchained, replacing a key is straightforward. You can simply log in to our platform, choose the key that has been compromised, and quickly replace it with a new one. You can read the full process for replacing or upgrading a hardware wallet at the link below, and if you’re already an Unchained client, check out our Knowledge Base article.

Visit Unchained.com for $100 off a Bitcoin IRA + 1 year free of Bitcoin Magazine Pro market research with code "btcmag"

Read more: How to replace or upgrade a bitcoin hardware wallet

You can construct multiple multisig wallets using the same devices

As we mentioned in number four on this list, using your hardware wallets/seed phrases for both a singlesig wallet and to construct a multisig wallet doesn’t cause any issues. Similarly, using your hardware wallets/seed phrases for more than one multisig wallet doesn’t cause a conflict among those wallets as long as you aren’t using the same extended public keys (xpubs). This is typically represented as a multiple accounts feature in most bitcoin wallets.

Hardware wallets allow you to use different xpubs from different derivation paths, which is a technical way of saying a different set of bitcoin keys on your hardware wallet generated by the same 12- or 24-word seed phrase. This means you can create multiple multisig wallets that stem from the same set of seed phrases/devices, like using the same devices for a personal vault and an IRA vault. Maybe even a loan vault as well!

Collaborative custody doesn’t introduce a single point of failure

When getting started with multisig collaborative custody at Unchained, one concern I hear a lot relates to dependence on our platform. If Unchained were to cease to exist or have significant downtime, how would you recover your funds if your wallets were constructed using our tools?

Our multisig platform is designed to eliminate all single points of failure, and that includes ourselves. As our platform is fully interoperable with established bitcoin standards, you can always recover access to your vault outside the Unchained platform with compatible software like our open-source multisig coordinator, Caravan, or bitcoin wallets like Sparrow or Electrum. Just make sure to safely back up your wallet configuration file!

Read more: How can I recover my vault funds using Caravan?

Originally published on Unchained.com.

Unchained is the official US Collaborative Custody partner of Bitcoin Magazine and an integral sponsor of related content published through Bitcoin Magazine. For more information on services offered, custody products, and the relationship between Unchained and Bitcoin Magazine, please visit our website


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EU Parliament Adopts AML Laws Regulating Bitcoin Based On Questionable Assumptions

EU Parliament Adopts AML Laws Regulating Bitcoin Based On Questionable Assumptions

The European Parliament adopted a new AML law package which increases the reporting requirements of crypto asset service providers (CASPs) when sending and receiving ‘anonymous’ payments between self-hosted wallets and custodial service providers, in addition to limits on cash transactions and the establishment of a ‘central watchdog’ agency, which will develop regulatory technical standards.

Under the new laws, EU CASPs will need to perform customer due diligence on transactions originating from self-custodial wallets for transactions below 1000 EUR, and implement additional KYC measures for transactions above 1000 EUR. The laws further regulate the operation of no-KYC custodial software service providers and the use of privacy coins, effectively banning CASPs from offering privacy assets. Self-custodial software and hardware providers are exempt from the regulations.

The resolution, adopted by the European Parliament on wednesday, assumes that “[t]he anonymity associated with certain electronic money products exposes them to money laundering and terrorist financing risks,” and “[t]he anonymity of crypto-assets exposes them to risks of misuse for criminal purposes.”

While lawmakers seemed to have no issues putting numbers to overall money laundering activity in the original proposal – ranging between 2-5% of global GDP – as well as to their own inefficiencies – almost 99% of criminal profits escape confiscation – those looking for numbers corroborating “the increasing use of crypto-assets (such as Bitcoin) for money-laundering purposes” are left with a link to Investopedia, explaining what Bitcoin is.

Everybody knows: Crypto is for money launderers. But can anybody prove it?

With the new law package, EU AML/CFT frameworks are updated to align with updated recommendations issued by the Financial Action Task Force – an intergovernmental body established by the G7 in 1989 to tackle money laundering and terrorist financing.

According to FATF procedures, FATF recommendations are informed by AML and CFT assessments performed by FATF regional bodies (FSRBs), the IMF, and the World Bank to “produce objective and accurate reports of a high standard in a timely way,” “[e]nsure that there is a level playing field, whereby mutual evaluation reports (MERs), including the executive summaries, are consistent, especially with respect to the findings, the recommendations and ratings,” and “[e]nsure that there is transparency and equality of treatment, in terms of the assessment process, for all countries assessed.”

The latest EU FSRB 2021 annual report, released in April 2023 performed by the EU Commission's MONEYVAL, opens with a introduction by the chair, who highlights that “It is well known that money launderers have been abusing cryptocurrencies from their inception a decade ago, initially to transfer and conceal proceeds from drug trafficking. Nowadays, their methods are becoming ever more sophisticated, and larger in scale.”

But MONEYVAL’s report appears to fail to back its claims with sufficient data points, merely making note of the progress of implementation of virtual asset regulations. The report highlights that “a 2022 typologies study will be dedicated solely to cryptocurrency money laundering trends,” suggesting that no such study existed at the time of writing.

The MONEYVAL typologies report on money laundering and terrorist financing risks in the world of virtual assets seems to give no conclusive answers on the significance of cryptocurrencies in AML/CFT efforts either; Instead, it analyzes the application and effectiveness of existing AML regulations via working groups.

Notably, the typologies report states that “at the national level, the sector risk analysis heavily relies on the answers received by the authorities from the private sector itself, with very little action taken towards the verification of the facts by the supervisor.” It further notes that risk assessments “lack in depth.”

The latest IMF report on policies for crypto assets makes similar statements hinting towards a lack of verifiable data on the risks of cryptocurrencies in terror financing, anti-money and financial abuse, stating that “such impacts have not been studied specifically in relation to crypto-assets“. A new IMF report released this week, which attempts to analyze cross border-flows in Bitcoin, states that “measuring Bitcoin cross-border flows is challenging, and currently only possible with a series of non-trivial assumptions.”

The IMF’s 2024 global financial stability report in contrast does cite specific data, but places the overall amount of cryptoassets received by ransomware hackers at approximately $1100 Million – a mere 0.061% of crypto’s $1.8 Trillion market capitalization.

The World Bank’s 2023 report on lessons learned from the first generation of money laundering and terrorist financing risk assessments found that “some new issues were not covered in the last NRA, such as VA [virtual asset] [...]”, and that it should be ensured that “authorities and private entities provide more data for input” and “assess more risks such as VASPs.”

A World Bank 2022 publication on national assessments of money laundering risks makes no mention of cryptocurrencies at all, beyond finding that virtual currencies should be “studied further”. The paper “Illicit Transaction Flows: Concepts, Measurement and Evidence” published in the World Bank Research Observer in 2020, makes no mention of virtual assets, bitcoin or cryptocurrencies either.

Papers published by the World Bank on crypto asset adoption do not provide much more insight into the impacts of cryptocurrencies on AML/CFT efforts either – The papers “Crypto-Asset Activity around the World” and “What Does Digital Money Mean for Emerging Markets and Developing Economies?” simply re-refer readers to existing FATF recommendations.

The World Bank paper “Decrypting New Age International Capital Flows” cites a single academic paper on the effects of cryptocurrencies on money laundering, claiming to have found that “approximately one-quarter of bitcoin users are involved in illegal activity.” While there are many scientific papers attempting to assess the significance of cryptocurrencies in illicit transaction flows, academics broadly question the accuracy of applied methodologies, claiming to have found error rates of over 92% in commonly applied heuristics. Particularly methods based on user behavior are argued to be “the most unreliable”, concluding that their application should not be used to warrant intense investigative measures.

Assessing Proportionality: National Security vs. Human Rights

Estimates of illicit transaction volumes range between 0.34% in all on-chain transaction volume in 2023 and 46% of all bitcoin transaction volume in 2019, highlighting the apparent lack of a conclusive understanding of the significance of cryptocurrencies in enabling the facilitation of illicit transactions.

In a 2024 National Risk Assessment, the Swiss federal police classifies such “tremendous lack of data” as an “inherent risk”, citing “insufficient figures and statistics”. The assessment highlights that the lack of data on cryptocurrency financial flows is “not unique to Switzerland”.

The assessment highlights statements made by the ECB, which “pointed to a lack of reliable statistics” on financial flows associated with cryptocurrencies. It further highlights statements made by the IMF, finding that “significant data gaps continue to make it difficult to assess the true extent of VA [virtual assets] use in the financial system, which also hampers risk analysis by financial authorities”. It notes that the IMF has recommended to initiate an international exchange of statistical data on cryptocurrency transactions to “address the lack of data” as early as 2019.

Seemingly echoing MONEYVAL’s concerns on the evaluation of suspicious transaction reports, the assessment finds a survey conducted among national police and prosecutors to gather quantitative information on criminal proceedings in cryptocurrency transactions and qualitative assessments of the challenges of cryptocurrency for the work of law enforcement to be “fragmentary” and “of limited relevance”.

Cybersecurity experts warn of the risks of cryptocurrency deanonymization tactics in relation to established fundamental rights, finding that future regulatory concepts may collide with fundamental rights such as the right to freedom of association, the right to privacy and the right to informational self-determination, the right to freedom of expression, and the right to freedom of information as established in the Charter of Fundamental Rights of the European Union as well as the European Convention on Human Rights.

As governed by article 5 of the Maastricht Treaty, actions applied by the European Union “shall not exceed what is necessary to achieve the objective of the Treaties.” It is questionable how MEPs have issued an informed vote on the proportionality of the EU’s new AML laws when no conclusive data on the significance of cryptocurrency in anti-money laundering and counter terrorist financing efforts appears to exist.

 This is a guest post by L0la L33tz. Opinions expressed are entirely their own and do not necessarily reflect those of BTC Inc or Bitcoin Magazine.


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FBI Warns Americans Against Using Non-KYC Crypto Money Transmitting Services

FBI Warns Americans Against Using Non-KYC Crypto Money Transmitting Services

The FBI has issued a public service announcement today, warning Americans against using unregistered and non-Know Your Customer (KYC) cryptocurrency money transmitting services.

This announcement, identified as Alert Number I-042524-PSA, urged Americans to only engage with registered Money Services Businesses (MSBs) that comply with anti-money laundering (AML) regulations.

According to United States federal law, cryptocurrency money transmitting services must be registered as MSBs and adhere to AML requirements (31 U.S.C. § 5330; 31 CFR §§ 1010; 1022). The FBI says failure to comply may result in financial disruptions during law enforcement actions, particularly if funds are mixed with illegally obtained money.

The warning clarified that services that knowingly facilitate illegal transactions or violate federal laws are subject to investigation by law enforcement agencies, and that individuals using such services may lose access to their funds during enforcement operations.

Just yesterday, the US Department of Justice (DOJ) arrested the founders and CEO of popular privacy focused Bitcoin wallet and mixer, Samourai Wallet, and charged them with laundering “more than $100 million in criminal proceeds.” The DOJ then worked with law enforcement in Portugal and Iceland to arrest one of the founders, and seized Samourai's web servers and domain, in addition to serving a seizure warrant on the Google Play Store for its mobile app.


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One of Only Four Bitcoin "Epic Sats" Just Auctioned Off For Over $2.1 Million

One of Only Four Bitcoin "Epic Sats" Just Auctioned Off For Over $2.1 Million

Today, Bitcoin mining pool ViaBTC auctioned off its “epic sat” for a sum of 33.3 BTC, equivalent to over $2.1 million. The auction, conducted on the CoinEx exchange platform, witnessed fervent bidding as collectors and enthusiasts competed for this satoshi.

The term "epic sat" refers to the first satoshi (the smallest unit of Bitcoin) of each halving epoch. A halving epoch occurs approximately every four years, coinciding with a reduction in the block reward for Bitcoin miners. These "epic sats" are part of the Ordinals numbering system, which categorizes satoshis based on rarity and significance within Bitcoin's historical milestones.

ViaBTC recently mined block 840,000, initiating the fourth Bitcoin halving and receiving this "epic sat" in the process. With the auction starting at a bid of 1 BTC, currently worth $64,000, bidders battled and drove up the price to the winning bid of 33.3 BTC worth $2,134,452 at the time of writing.

The Ordinals numbering scheme has sparked both controversy and excitement since its inception, creating an emerging market for satoshi collectors and investors. The rarity levels within Ordinals range from “common” to “mythic”, with "epic sats" standing out as among the rarest and most sought-after satoshis due to their occurrence only at each halving epoch.

Marketplaces specializing in Ordinals have seen increased activity, with rare satoshis fetching prices well above their nominal value. This trend has garnered widespread attention from miners, developers, investors, and collectors alike, due to their rarity and the growing interest in collectible satoshis. The winning bid of 33.3 BTC reflects the high demand for these sats and the willingness of collectors to pay a premium for them.

The auction of this “epic sat” for over $2.1 million signifies the cultural and historical significance these rare sat" hold within the Bitcoin community. As Bitcoin's ecosystem continues to evolve, the market for rare satoshis and related assets is expected to grow, offering new opportunities and strategies for participants in the Bitcoin market.


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Bitcoin Mixing Service Samourai Wallet Founders Arrested, Charged With Money Laundering

Bitcoin Mixing Service Samourai Wallet Founders Arrested, Charged With Money Laundering

In a significant development, Keonne Rodriguez and William Lonergan Hill, founders and CEO of the privacy-focused Bitcoin wallet and mixer, Samourai Wallet, have been arrested and charged with money laundering and operating an unlicensed money transmitting business. The U.S. Department of Justice (DOJ), Southern District of New York, announced these charges today following an extensive investigation into their activities.

The charges stem from allegations that Rodriguez and Hill, through their company Samourai Wallet, facilitated over $2 billion in unlawful transactions and allegedly laundered more than $100 million in criminal proceeds. This activity primarily involved transactions from illegal dark web markets, as well as schemes to defraud decentralized finance protocols, the DOJ stated. The defendants are accused by the DOJ of developing, marketing, and operating a bitcoin and cryptocurrency mixer that provided a platform for criminals to engage in large-scale money laundering.

“$2 billion in transactions with an unlicensed money transmitter means $2 billion flowed without any oversight, from whomever to wherever. Because of the company’s disregard for regulation, it’s alleged that Samourai Wallet laundered more than $100 million in criminal proceeds,” stated IRS-CI Special Agent in Charge Thomas Fattorusso. “Special Agents with IRS:CI New York and IRS:CI LA’s Cyber units worked with our federal and international law enforcement partners to not only arrest the founders and CEO, but to also seize their domain. Samourai Wallet is now closed for business.”

The coordinated effort by law enforcement agencies led to the arrests of Rodriguez and Hill. Rodriguez was apprehended in the Western District of Pennsylvania, while Hill was arrested in Portugal based on the U.S. criminal charges. The United States plans to seek Hill's extradition to stand trial in the country.

"As alleged, Keonne Rodriguez and William Lonergan Hill are responsible for developing, marketing, and operating Samourai, a cryptocurrency mixing service that executed over $2 billion in unlawful transactions and served as a haven for criminals to engage in large-scale money laundering," said U.S. Attorney Damian Williams. "Rodriguez and Hill allegedly knowingly facilitated the laundering of over $100 million of criminal proceeds from the Silk Road, Hydra Market, and a host of other computer hacking and fraud campaigns. Together with our law enforcement partners, we will continue to relentlessly pursue and dismantle criminal organizations that use cryptocurrency to hide illicit conduct.”

Furthermore, in collaboration with authorities in Iceland, Samourai's web servers and domain were seized, along with a seizure warrant served on the Google Play Store for the Samourai Wallet mobile application. This action ensures that the application is no longer available for download in the United States.

FBI Assistant Director in Charge James Smith concluded: “Threat actors utilize technology to evade law enforcement detection and create environments conducive to criminal activity. For almost 10 years, Keonne Rodriguez and William Hill allegedly operated a mobile cryptocurrency mixing platform which provided other criminals a virtual haven for the clandestine exchange of illicit funds, the facilitation of more than $2 billion in illegal transactions, and $100 million in dark web money laundering. The FBI is committed to exposing covert financial schemes and ensuring no one can hide behind a screen to perpetuate financial wrongdoing.”


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The Ultimate Guide to Bitcoin Self-custody for Miners

The Ultimate Guide to Bitcoin Self-custody for Miners

Originally published on Unchained.com.

Unchained is the official US Collaborative Custody partner of Bitcoin Magazine and an integral sponsor of related content published through Bitcoin Magazine. For more information on services offered, custody products, and the relationship between Unchained and Bitcoin Magazine, please visit our website

As a bitcoin miner, you have a lot to manage, from seeking out inexpensive electricity, to constructing facilities, to acquiring rigs and building a knowledgeable team that can keep them hashing. In speaking with mining companies over the years, we know that bitcoin custody is often an afterthought.

Here we’ll describe the process of securing your mined bitcoin in self-custody while managing a bitcoin treasury, CapEx, OpEx, OpSec, LP distributions, taxes, and more. Given the ever-present risks of hacks and suspended withdrawals, our goal is to explain the benefits and trade-offs of various approaches to bitcoin self-custody—regardless of the size of your operation.

Bitcoin self-custody considerations for miners

There are unique challenges miners face with self-custody in comparison to other types of bitcoin holders:

  • Miners receive a high frequency of incoming deposits from mining pool payouts, which can increase transaction costs due to UTXO bloat (more on this below).
  • Some portion of mined bitcoin must be sold to cover overhead.

Other challenges are similar to that of other businesses that hold bitcoin:

  • Businesses may not have the in-house expertise needed to set up self-custody securely while minimizing complexity.
  • Businesses generally have multiple operators and desire distributed control over bitcoin funds.
  • Businesses want to minimize counterparty risk while eliminating the risks of malware, user error, storage media decay, phishing, physical attacks, and other security risks.

In all cases, holding the private keys to your organization’s bitcoin should be prioritized. As we’ll explain next, multisig can enhance the security of your bitcoin regardless of your organization’s size. While the details of your setup may vary, multisig helps to address many of the above concerns while allowing your bitcoin to touch exchanges only when necessary (e.g., for OpEx/CapEx).

Upgrade your Bitcoin security and get access to exclusive discounts on Unchained financial services. Visit our website to learn more.

Why miners need multisig

Better security than singlesig

Singlesignature (singlesig) wallets—controlled by a single key secured by a Trezor or Ledger hardware wallet, for instance—improve security, reduce counterparty risk, and remove exchanges as a single point of failure. With singlesig, however, your bitcoin is put at risk if a hardware wallet or seed phrase is lost or compromised. Just one or the other, in the wrong hands, could lead to permanent loss of funds.

Multisignature wallets, on the other hand, enable you to store bitcoin in a wallet controlled by multiple keys. They increase your security by ensuring more than one of those keys, held in different locations, are required to sign a transaction. If set up correctly, multisig can eliminate all single points of failure. For a miner, this means removing the risk of a single rogue employee moving funds, and creating redundancy so that the loss of a single hardware wallet or seed phrase cannot lead to a critical loss of funds.

Eliminates exchange custody risk

Exchanges can be a convenient place to send newly-mined bitcoin. They allow you to easily exchange bitcoin for your local fiat currency before sending funds to a linked bank account, and they even take care of things like UTXO management. In bitcoin, however, there is always a price to pay for convenience. The risks and potential downsides of using an exchange for key storage are numerous—the fact that they can cut you off at any time and the possibility of hacks and insolvency are only the beginning.

Flexibility to achieve an ideal balance of security and complexity

A 2-of-3 multisig quorum has three total keys where two are required to spend, which keeps your bitcoin secure even if one key is compromised. Many mining firms find that 2-of-3 multisig is the perfect setup for their corporate treasury because no single individual can compromise the entire treasury, while sending out LP payouts and monthly expenses is still kept straightforward (only two signatures required).

Higher-quorum multisig (e.g., 3-of-5, with five total keys and three required to spend) adds more keys and typically more individuals to the equation. This can technically improve the security of your bitcoin wallet in some cases—but also dramatically increases complexity. We wrote a comprehensive article explaining why this is the case, but for the purposes of this article, you just need to know the sweet spot for most individuals, organizations, and mining operations tends to be 2-of-3.

Fault-tolerance of a typical 2-of-3 multisig collaborative custody setup compared to a seedless 3-of-5 setup

The benefits of collaborative custody

When using multisig for your mining company’s treasury, you might also benefit by including an institution (like Unchained) to hold one of three keys for your multisig setup.

In addition to the enhanced security that multisig provides, collaborative custody can also help with:

  • Reduces the number of physical items (hardware wallets and seed phrases) you need to secure.
  • Active monitoring over suspicious activity like unauthorized transaction signatures or account logins
  • A partner that can help your team recover the wallet in the event where one of your keys has been lost or compromised.

Wallet management

Managing mining pool payouts

Every miner needs to make decisions on security, transaction cost, and counterparty risk when deciding which type of wallets to use for their newly mined bitcoin.

Below are four example workflows that may help you determine which model is the best for your mining operation.

Workflow #1: Mining pool payouts sent to a singlesig wallet

In this popular workflow for smaller mining operations, you receive mining pool payouts directly to a singlesig wallet controlled by a single operator. Funds that need to be sold can then be sent to an exchange, while funds to be stored long-term are sent to a multisig wallet.

Workflow #2: Mining pool payouts sent to a multisig wallet

This workflow is the same as the workflow described above, except that mining pool payouts are sent to a multisig wallet instead of singlesig. A second multisig wallet is required for the corporate treasury.

Sending bitcoin payouts direct to multisig maximizes security throughout the workflow, but requires two people to approve each transaction to the exchange and treasury. As such, it is better suited for larger mining operations.

“With multisig you’re paying higher fees to remove counterparty risk.” – Griffin Haby, Mountain Lion Mining

Workflow #3: Split payouts from the mining pool

Some mining pools allow miners to split payouts between two or more accounts. In this workflow, we show automating the payout process to send a fixed percentage directly to cold storage, and the rest to an exchange to sell to cover overhead.

Workflow #4: Mining pool payouts sent to an exchange

In this workflow, bitcoin is mined directly to an exchange. This is far more convenient for the purposes of UTXO and fee management purposes, and allows immediate liquidation of funds, but leaves bitcoin in the most vulnerable state for the longest amount of time, with high counterparty risk.

Maintaining multiple fund buckets

Even within the above high-level approaches to bitcoin security, you may want to further separate wallets for separate purposes, like distributions, operating expenses, or corporate treasury. Keeping these buckets of bitcoin cryptographically separated from each other will make it far easier to keep track of your operation from a tax and accounting standpoint—and much easier to ensure those long-term satoshis aren’t being used for overhead!

Managing transaction fees

Miners are typically more concerned with collecting transaction fees from other users. However, when managing your bitcoin mining wallets, the fees you pay when sending bitcoin—whether to an exchange, cold storage, or investors/partners—should also be considered.

As we described in a previous article, bitcoin transaction fees depend on how congested the bitcoin network is at any given time and how much data is being processed in a transaction. One of the key factors behind the data size of a transaction is the number of UTXOs involved. Our article on the problem of too many UTXOs is a good primer on UTXO consolidations, payout thresholds, and how bitcoin transaction fees are calculated.

As a miner, there are four main ways you can reduce your transaction costs:

1. Increase payout thresholds from mining pools

If you use a mining pool, and take a high frequency of payouts, it’s going to result in a lot of small UTXOs in your destination wallet, which could be expensive to spend when the time comes.

To mitigate this, you can increase your pool payout threshold to reduce the number of deposits being made to your wallet (and therefore reduce the wallet’s UTXO count). This method is especially useful for future fee mitigation if you are pointing your payouts directly to a multisig wallet (which requires more data to make a transaction than a singlesig wallet).

2. Manually consolidate your UTXOs

You can further reduce the number of UTXOs in your wallet by periodically consolidating. This is a relatively simple process; you just need to author a transaction containing the UTXOs you wish to consolidate, and send them back to yourself. You can learn more in our article covering strategies to manage too many UTXOs.

3. Set a low fee…and wait

Block space is limited by design—the higher the demand for space (increased quantity of transactions), the higher fees will be. If you don’t need a transaction to be processed immediately, consider setting a lower fee rate than recommended at the time of sending. This makes the transaction take longer to process, but can help you avoid paying excessive fees during periods of high demand.

At any given time, there is a minimum fee rate the mempool is willing to accept. Typically, this stays between one to three sats/vbyte. Current fees can easily be viewed on most block explorers, such as mempool.space.

4. Batched spending

Miners who need to send multiple payments at the same time can reduce transaction fees by sending them all at once using a transaction method called batching. This method of consolidating multiple payments can be performed with many popular bitcoin wallets (such as Bitcoin Core, Electrum, or BlueWallet) and can be helpful for LP distributions or any other time you need to make multiple transactions at once.

Key management

Identify your keyholders

When your company decides to hold the keys to its bitcoin you will need to determine who at the company will physically hold the keys.

The goal is to distribute control over keys and seeds evenly. This gives no one person the ability to sign a transaction or move bitcoin on their own. What this looks like for your organization will depend on your specific circumstances, such as the number of principals, the number of keys, and whether the wallet is for long-term storage or simply distributing control over spends.

In the above example where you’ve decided to use 2-of-3 multisig for your mining operation’s bitcoin treasury (we’d typically recommend this), you might select the company’s CEO and CFO to hold a key each, and a collaborative custody partner to hold the third key.

Properly secure your hardware wallets and seed phrases

There are typically two separate physical items to protect for each of your company’s bitcoin keys: a hardware wallet and a seed phrase. A critical element of implementing a secure multisig model is the geographical distribution of hardware wallets and seed phrases so that no single physical location is a point of failure for your bitcoin.

Seed phrases are worth particular attention because they are a physical and unencrypted copy of your bitcoin private keys. You should always retain seed phrase backups of your keys to reduce the reliance on sometimes finicky hardware wallets.

The location of the hardware wallets and seed phrases should only be known to individuals who will be expected to provide transaction signatures to move bitcoin. Keep in mind: When storing and securing these items, you may want to ensure that no single person at your organization has seen or knows the location of the necessary hardware wallets or seed phrases to spend—so that no single person can compromise your bitcoin treasury.

Ongoing key maintenance

Key hygiene

After you’ve properly stored your hardware wallets and seed phrases, there are a few best practices you should observe to keep the device and data on the device in proper working order:

  • Keep the firmware up to date: This should be done roughly two to three times a year to ensure your hardware wallets have the best security, newest functionality, and will work to sign transactions when you need to.
  • Perform key checks: At regular intervals, check that your hardware wallets are functional and check the physical security of your seed phrases. We recommend this should be done roughly four times a year.

Changing key holders

When a key holder leaves your mining operation, you should always replace their key as soon as possible. Don’t simply hand over the old key to a new key holder—that would be a a potential security hole. Even if the original key holder can be trusted and left in good standing, replacing the key reduces the risk that unauthorized signatures will be performed or attempted in the future.

Key replacements

To replace a key, you will need the new key holder to generate a new key, (if using multisig) create a new multisig wallet with the new quorum, and then (carefully) send all the company’s bitcoin to the new wallet.

If you’re using collaborative custody with Unchained Capital, our platform can safely guide you through the key replacement process. If you’re not using a collaborative partner, we’d recommend having someone technical on hand to help with the process.

  • For Unchained Capital clients needing help with key replacements, reach out to your dedicated account manager or client services.
  • If you are unsure whether or not you need to perform a key replacement, or if you would like to learn how key replacements for multisig work technically, you can refer to this article.

Other considerations

Bitcoin mining and taxes

Bitcoin miners are responsible for understanding and abiding by local and federal tax regulations. Taxes and accounting as they pertain to bitcoin mining are beyond the scope of this guide, but they are relevant considerations and you should consult with an accountant or tax professional to learn more.

For US-based miners, Unchained’s Head of Legal Jeff Vandrew briefly touched on the topic of mining and taxes in his piece covering what you need to know about bitcoin mining, IRAs, and taxes:

If a taxpayer obtains bitcoin through mining, they must recognize income in the amount of the fair market value in U.S. dollar terms of the bitcoin received on the date of receipt. That recognized income is subject to income tax at ordinary income tax rates. On top of income tax, the taxpayer may also be subject to self-employment tax.

Get $100 off Unchained IRA and receive 1-year free of Bitcoin Magazine Pro market research ($250 value). Visit unchained.com and enter code “btcmag” at checkout.

Selling bitcoin

If you do need to convert bitcoin to your local currency to pay bills, taxes, or cover overhead, you may want to expedite the process by setting up an exchange account and linking an active bank account. Some exchanges can take days or weeks to approve new accounts, so plan accordingly, especially if you are up against a deadline like paying an invoice, payroll, or taxes.

Unchained Capital can help facilitate the purchase or sale of bitcoin straight to or from a multisig vault, within certain limits, for companies and individuals in the U.S. that reside in a state where our trading desk is active.

Collateralizing your bitcoin

Securing your bitcoin with a collaborative custody partner like Unchained Capital means you can easily use that bitcoin to access liquidity to reinvest in your mining operations—without ever selling your bitcoin. For more detailed information on bitcoin collateralized lending, visit unchained.com/loans.

Let Unchained Capital be your guide

Whether it be the daunting task of managing fees, advice on how to structure your bitcoin custody workflow, or access to a trading desk to buy and sell bitcoin, we’re here to help. Our multisig vaults for business give your organization complete control over your bitcoin while providing a trusted partner to guide you and your team through setup and to help with key replacements and wallet recovery if and when necessary.

Originally published on Unchained.com.

Unchained is the official US Collaborative Custody partner of Bitcoin Magazine and an integral sponsor of related content published through Bitcoin Magazine. For more information on services offered, custody products, and the relationship between Unchained and Bitcoin Magazine, please visit our website


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