News.Bitcoin.com Lead Writer Jamie Redman Named One of the

a conversation with patrick dugan about aml/kyc in tether and the coming cryptofiat money laundering / law enforcement wars

patrick dugan: Interview with Jamie Redman at Bitcoin.com thomas hartman: nice interview. from the transcript: “Personal speculation convinces me that If we have 100 million decentralized dollars backed by OMNIs, then the price of OMNI could be around 100M/580k= $172.41,” thomas hartman: seems moon juicy to me though… thomas hartman: these are claims are dollars, not the dollars themselves. thomas hartman: there’s still counterparty risk (if debt tokens) or system risk (if decentralized hedged) thomas hartman: I can’t see how there could be 1 to 1 parity. thomas hartman: also this would be competing with systems built on open assets and others. thomas hartman: anyway… the thought running through my head these days is… tokenize everything. thomas hartman: transparent books, the less in a database the better. thomas hartman: counterparts keep you honest. thomas hartman: keep trust low. thomas hartman: that’s what will drive valuations. patrick dugan: what's really interesting is when you make tokens basically logic switches of some kind in a dApp structure with smart contracts thomas hartman: yeah I agree with that patrick dugan: we'll be publishing cool charts soon thomas hartman: related.. I’m unclear on kyc/aml for tether. thomas hartman: I understand you need to pass kyc/aml when cashing out of tether system. thomas hartman: so… what if user a buys some tether after passing kyc/aml. thomas hartman: he tumbles the tethers. sells for btc on polonium to user b. thomas hartman: user b now wants to cash out tethers for real use. he passes aml/kyc as far as identity check. thomas hartman: but anyone can see the tethers have been tumbled and the link is broken. thomas hartman: so this could be part of some money laundering operation. thomas hartman: would tether cash user b out? thomas hartman: seems to me like these tethers would be significantly less liquid than untumbled tethers, and therefore less valuable. thomas hartman: i.e. maybe you get used in the end but there’s a long/annoying wait period while you get probed. thomas hartman: or maybe you’re targeted for a criminal investigation. thomas hartman: academic while tether volumes are low but as the system ramps up in volume, this will happen at some point. thomas hartman: answers from team tether would be nice. thomas hartman: the key intuition is that anything that’s a token can be tumbled. thomas hartman: well, if the anonymity set is large enough. thomas hartman: so… if we’re going to tokenize everything............ thomas hartman: when does the aml/kyc ban hammer slam down? thomas hartman: if you think it’s going to slam down soon, you should probably buy ripple thomas hartman: not soon, or maybe never, bet on strong mixable tokens like omni / open assets patrick dugan: I spoke with the CEO of Bitfinex about letting people buy BTC without a verified account patrick dugan: just deposting it, trading it, withdrawing it patrick dugan: for banks and Tether they have a verified req. patrick dugan: I think from a regulator's point-of-view patrick dugan: there is a boon to all this patrick dugan: because Tumbling is predicated on the liquidity of the tumble pool patrick dugan: so you can build evidence against those guys patrick dugan: charge them all with money laundering, but later thomas hartman: that’s interesting. patrick dugan: and non-tumbled blockchain is pretty great for investigators patrick dugan: just run a regression and collate that with whatever else you have, you just need to pint an eye and a nose to pin the tail on the donkey thomas hartman: essentially this means there is arms race / cat and mouse analogous with $10k use limits currently in place for cash. patrick dugan: so they get the eye from the exchanges which would be otherwise block boxes thomas hartman: you’ll be able to tumble, but only small amounts. patrick dugan: yeah I'm not really worried about it thomas hartman: you can tumble large amounts by batching small amounts under sock puppet’s identities patrick dugan: I had my coming to ceasar moment recently thomas hartman: sometimes regulators will look the other way thomas hartman: and sometimes they will make an example out of you thomas hartman: exactly as now. thomas hartman: I guess that’s how it thomas hartman: it’s going to play out. patrick dugan: All I care about is that we're doing things by the book and so too the organizations we endow, though there is a reg. arb at work there in that we typically endow in jurisdictions that are way more chaotic than the US. thomas hartman: there’s some gray area allowed in the fiat system, because otherwise the peasants revolt if you don’t allow them some degree of privacy thomas hartman: the exact boundaries of the gray area are gray, because that gives you maximum flexibility in terms of who you lock up, how you play favorites, etc. patrick dugan: the interesting thing about publishing an algorithm for free and letting anyone combine collateral like BTC with trading some hedge to issue pegged currency, is that it's a true bearer asset, and essentially everone can do it patrick dugan: so the threshold of revolt you mention patrick dugan: well that's a dialectic for all System D economic growth that governments want to tax to some degree patrick dugan: will blockchain-ization of that shadow economy make it easier or harder for regulators patrick dugan: on decentralized chains maybe harder patrick dugan: on Ripple/Hyperledger-esque systems patrick dugan: easier! patrick dugan: much much easier patrick dugan: it would completely transform the situation in Greece of Argentina patrick dugan: assuming the gov cut rates to a lower level and taxed everyone affordabblly patrick dugan: which is perhaps more credit than I'm willing to give them patrick dugan: but the decentralized economic history is stil history that anyone can analyze patrick dugan: that's why Ecuador is smart patrick dugan: they got ahead of the curve thomas hartman: you won’t be able to get amld/kycd account with tether if you’re in a proscribed country like argentina or greece. but I guess you’ll always be able to get in and out with bitcoin. thomas hartman: the end effect is that tether on poloniex should be worth slightly less than a dollar thomas hartman: but hopefully not too much less patrick dugan: well anyone with verified accounts can arb it patrick dugan: so the discount should be that profit margin patrick dugan: as competitive as it may get thomas hartman: that makes sense patrick dugan: what I've learned doing arb in this space for a while, competitive as it may get may take a long time to get competitive thomas hartman: of course, as soon as there are headlines of drug money or whatever on tether, the discount will increase patrick dugan: but that's part of what I'm doing with this role I play, growing capital by providing liquidity thomas hartman: because now you’re looking at the counterparty risk of the tethers being non-exchangeable while interpol does its thing patrick dugan: I think people will do drug deals - or whatever - with p2p escrow that bonds the payment pending the competion of the deal, and they'll prefer USD with a yield that is also p2p generated and redeemed patrick dugan: but ultimately the only way you institute a criminal penalty for people who publish software is to revoke the 1st amendment patrick dugan: so law enforcement will simply have to adapt to hiring guys who can crunch the data and do investigations aided by that thomas hartman: somebody will tumble + attempt redeem on tether, just to mess with the system patrick dugan: it's called work and it's what they're paid for patrick dugan: likewise mil.gov like NSA will have to adopt better encrypted infrastructure to avoid getting zapped by the Chinese thomas hartman: its not the people who publish the software (they can be anonymous), it’s inconveniencing the actual tether holders when they try to cash in patrick dugan: thing is Bitfinex and Tether are not part of the US SAR system as much patrick dugan: they are in the Eurodollar system already thomas hartman: there’s aml there too, and interpol and and and patrick dugan: so their regulator is the HK monetary authority or the Taiwanese superintendand of banks, and their regulators have not explicated that those who deposit/withdrawal crypto-assets to trade must be verified thomas hartman: but do you expect this situation to continue indefinitely? thomas hartman: especially given the certainty of this avenue for capital flight? patrick dugan: now what you're actually talking about would be like a court precedent to try someone who traded Tether and deposited it as an accomplice to money laundering thomas hartman: it’s just a temporary artifact probably patrick dugan: but in order to set a precedent there would have to be proof of mens rea thomas hartman: yes to your last comment (court precedent) patrick dugan: which is balatantly untenable considering the purely p2p nature of usage in a blind, fungible fashion patrick dugan: if that were possible, people who have handled cash or bitcoins could all be tried for money laundering thomas hartman: well it’s new territory here, but I wouldn’t expect territorial governments to essentially open the floodgates on money laundering / capital flight in fiat currency thomas hartman: just because of some wording on previous precedents thomas hartman: they will at least attempt to lock it down patrick dugan: I mean you're talking about the 1st amendment and the 4th thomas hartman: along the lines I described earlier (fuzzy limits with fuzzy boundaries) patrick dugan: I am not pro-money laundering patrick dugan: I am not Cody Wilson though I enjoy his videos thomas hartman: neither am I, I’m just trying to predict the future thomas hartman: in terms of how this will play out patrick dugan: a Dex is not, like what Wilson said of dark wallet "basically money laundering software" patrick dugan: the chain of addresses is still quite intact thomas hartman: but the tokens themselves can be mixed patrick dugan: I think you're overestimating how effective these tools are for enabling individual actors who are evidentiarily guilty of other crimes to get away with money laundering thomas hartman: at low cost of both time, money and effort (somewhat unlike current laundering techniques) patrick dugan: Dark Wallet sets a precedent where the publishers have free speech rights but arguably the users are accomplices in ML thomas hartman: yes, but bitcoin is infinitely fungible patrick dugan: but having a chain of addresses, and any address in the chain has meta-data associated, you can build a case super easily thomas hartman: with tether, you get stuck holding the hot potato when you try to convert to real dollars patrick dugan: it really helps LE in a lot of ways patrick dugan: tax evasion is the hariest because tax events need context, which is more meta-data than the KYC usually permits thomas hartman: so LE doesn’t have to attack the system, they can just put pressure on the central account keeper patrick dugan: well Dark Wallet being p2p is a precedent that really thumbs the nose patrick dugan: because your central account keeper is every user patrick dugan: so what do you track down IPs and subpeana everyone who downloaded dark wallet thomas hartman: but not the case in tether and similar systems patrick dugan: yeah Bitfinex would not have put their foot on the train tracks if it were otherwise thomas hartman: LE can go to tether and say “these are blacklisted tokens. don’t let users cash out to real dollars until you’ve cleared it with us" patrick dugan: no because they don't have jurisdiction thomas hartman: and I guess they probably will thomas hartman: someone has jurisdiction patrick dugan: they can however charge people with crimes, investigate, and prosecute thomas hartman: there are treaties patrick dugan: HK/Taiwan thomas hartman: there may be a window of confusion, but eventually enforcement will be automatic and global patrick dugan: right let's download those and figure out how, if we were lawyers on such a case, we might defend our client thomas hartman: we’re talking about national sovereignty at stake patrick dugan: anyway Bitfinex will certain disclose all info on Verified users that way patrick dugan: will it eventually? patrick dugan: I've been looking at the TPP thomas hartman: that’s my prediction patrick dugan: it's a NWO-style dealio patrick dugan: there is an agency in Chile that pays people to eat at restaurants and record for any unliscenced music plays patrick dugan: seriously thomas hartman: the ability to track money flows is a tremendous power, that world governments will not give up on lightly patrick dugan: that could apply to subjagating food supply if Monsanto sues a guy for an errant wind-blown grain and the courts ruling in the guy's favor makes the country liable for payments under TPP thomas hartman: essentially they already have for pure crypto, but when it comes to tokens on fiat money, they will up their game patrick dugan: they actually don't' quite have it now patrick dugan: tracking SWIFT through offshore banking centers is possible, but it's a job thomas hartman: sure, it falls into that gray area I was talking about patrick dugan: I just think you're assuming that unilateral authority applies more to various parties, whereas the reality is they hire guys at 150k to sit down and do the hard work thomas hartman: but boundaries are going to shift radically if governments don’t take steps thomas hartman: so my prediction is they will take steps, to preserve not exactly status quo, but not total revolution either patrick dugan: the smartest thing for TBTB to do is adopt Blythe's thing or Eris' thing or Ripple and save money, invite people to use the digital ledger for tax transacitons as well maybe with a credit or a lower rate, and get a bunch of IDs and economic volume in their ledgers thomas hartman: with laundering shifted to block chains the work will be harder in some ways, easier in others patrick dugan: I actually take the possibility of criminals getting away with ransoms and hostage kidnappings seriously patrick dugan: I have thought deeply about this thomas hartman: me too patrick dugan: because I have kids and can entertain paranoia patrick dugan: so ultimately in a place like Argentina, you could sell cold wallets with 10 BTC each to a guy for $1750 each maybe patrick dugan: at present rates patrick dugan: but can you sell 100 of those wallets? maybe the guy will work with you to make it happen patrick dugan: can you sell 100 a month, I don't know if that economy in Argentina is quite big enough patrick dugan: it comes down to the scale of liquidity in the rogue pool thomas hartman: I don’t follow you now patrick dugan: you can properly launder BTC for cash by finding a cash dealer thomas hartman: seems like you’d collect ransom via bitcoin, buy tether to control the exchange risk if you’re worried about that patrick dugan: but people are still laundering money predominantly (like 99.999%) in older methods because those are liquid thomas hartman: and go tether -> bitcoin -> tumbler -> exchange with fake user id -> usd thomas hartman: to spend it in fiat if that’s what you want patrick dugan: haha ransomer doesn't want to be long BTC patrick dugan: too risky thomas hartman: he doesn’t have to be, he can buy tether on poloniex thomas hartman: without passing aml. right? patrick dugan: no Tether now requires KYC for all users thomas hartman: ok, that makes things slightly harder. patrick dugan: though they treat Tether equally to any other coin on there patrick dugan: right so the whiz kid at FinCEN who graphs nodal density in BTC aaddresses is already tracking tumbler pools thomas hartman: got it, tether is functionally traceable like other coins, but requires aml/kyc unlike other coins thomas hartman: on every exchange that allows it patrick dugan: they can model where things go dark and what is coming back to the light from those pools patrick dugan: probably you can untangle BTC blockchain tumbling with the right algo thomas hartman: you could still buy tether via localbitcoin / wot though thomas hartman: “dark tether" patrick dugan: you need the same KYC to do 2k daily withdrawals in Tether as in Moneero or LTC or ETH ect. thomas hartman: no, you can’t untangle tumbling if done right thomas hartman: it currently isn’t done right for the most part, but again that’s just temporary patrick dugan: and p2p local bitcoins will be a thing patrick dugan: I think the only serious thorn in the side of monetary authorities is cash trading for crypto patrick dugan: done p2p, efficiently thomas hartman: currently yes, but that’ll change eventually patrick dugan: like here in Chile they have the Caja Vecina patrick dugan: corner store, bring them some cash, they deposit to your account associated with your ID number at the state bank patrick dugan: if that business model can percolate patrick dugan: and in which countries patrick dugan: like in Chile that's an ID'd, state controlled deal patrick dugan: has similar reach thomas hartman: hmmm interesting patrick dugan: Bolivia is doing a really good job with that as well patrick dugan: met their Payments Director at the cb in Miami the other week thomas hartman: cb? patrick dugan: but in Argentina perhaps patrick dugan: central bank patrick dugan: or throughout Africa patrick dugan: or in rural India patrick dugan: we could see cash/crypto trade that is unlicensed patrick dugan: we could see cash/crypto trade that is licensed patrick dugan: saw a guy on local bitcoins paying a premium for your BTC via cash deposit patrick dugan: but, he's in NYC, so he claims to have BitLicense patrick dugan: which means notes, notes patrick dugan: so you see the problem continues to migrate down the line from the platforms to the individual users, and the inherent degree that the platform, more true of distributed ledgers, automatically informs on bad actors patrick dugan: not without paying people well to do some challenging work, but it's all tractable math and computer science patrick dugan: oh also ring signatures may be the exception to that thomas hartman: well, except the tumbling / ring signatures as you say thomas hartman: it will definitely be possible to break the link thomas hartman: and leave only timing attacks on the anonymity set patrick dugan: an rs blockchain like Moneero, with smart contracts and the growth potential that I am trying to galvanize on Bitcoin, so trillions in System D liquidity in this shadow chain, that could really be a threat to KYC status quo thomas hartman: only a matter of time thomas hartman: confidential transactions on a future bitcoin gives you essentially the same deal thomas hartman: best to treat all these anonymity techs as esentially already done deals when you’re trying to predict the future, imho patrick dugan: yeah but 100,000,000 system d merchants don't think the same way as the 89,000 Poloniex account holders thomas hartman: doesn’t really matter which token they happen in, or all of them, since tokens are interchangeable via exchanges patrick dugan: I wouldn't consider anything a done deal patrick dugan: because user acq. is hard for a social game patrick dugan: it's really hard for money apps patrick dugan: because people need to not just trust it but be comfortable with it patrick dugan: I was just barely comfortable rigging the Geth CLI to fire off some Ether patrick dugan: and I work in this biz patrick dugan: so scale that on down thomas hartman: it’s not a done deal of course, but when you’re doing psychohistory you need to make simplifying assumptions… identify the critical juncture points patrick dugan: if anything I should be more conservative about estimates of adoption thomas hartman: yes I think you should be thomas hartman: aim for traction on small scales in identifiable markets thomas hartman: rather than boiling the ocean thomas hartman: but I think overall you’re doing a great job thomas hartman: tether is a real thing. it’s being used. just figure out what works, and keep growing that. patrick dugan: thank you for your kind words 
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Bitcoin Writer, Bitcoin Family, Island Life - Jamie Redman

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