back to article Money laundering and crypto-coin legislation could hurt open-source ecosystem – activists

The Electronic Frontier Foundation (EFF) and UK Open Rights Group have responded to an HM Treasury consultation on money laundering legislation, in particular to the suggestion that publishing open-source software should be subject to customer due diligence requirements. The Transposition of the Fifth Money Laundering …

  1. LucasNorth

    This is not a problem. I work for a company that pretends to use a blockchain and I can tell you that blockchain is a worthless technology. Anything that makes companies less likely to waste their time on this nonsense technology has to be a good thing

    1. DuncanLarge Bronze badge

      Ahh, old timers

      Enjoy living in the past. Rose coloured specs are on special offer.

      I hardly ever say something like that as I'm quite the retro head. I love broadcast radio, CD audio and its standards, record to minidisc and minidv tapes. I'm an optical media obsessive.

      But here, I see something totally different. I see the future of human economy. A future where wealth is more universal.

      Game of Thrones showed us the "Breaking of the Wheel" of inheriting power over others through bloodlines. I think that blockchain technology, certainly in the form of digital currency, is the breaking of the wheel of holding power over people through wealth. At least the start of it.

      Now all we need are replicators or 3D printers that can print with more than polymers and we have the start of the new world economy. Unfortunately some of that will be too much scifi for anything within my lifetime...

      1. katrinab Silver badge
        Flame

        Re: Ahh, old timers

        Can a blockchain shill please complete the following sentence with something reasonable:

        The problem with MasterCard is [...]

        So far I've had:

        "The problem with MasterCard is that you can do chargebacks on fraudulent transactions"

        "The problem with MasterCard is that there is a trusted intermediary who you can complain to if things go wrong"

        "The problem with MasterCard is that there are transaction fees" (Note that Bitcoin transaction fees tend to be higher, also, don't forget the increased insurance / security costs associated with Bitcoin)

        "The problem with MasterCard is that it takes up to a month for the transaction to go through the system" (I've timed it. It is usually about 8 seconds, way faster than Bitcoin).

        As for non-currency related uses of blockchain, replace blockchain with computer file, and smart contract with computer program. You can do exactly the same things. Blockchain is about as exciting as anti-virus software or backup software.

        1. jmch Silver badge

          Re: Ahh, old timers

          The problem with MasterCard is that every transaction is tied to your identity. That might not be a problem if you trust your financial institution with your data, and if you trust your benevolent government to never abuse its power.

          It's more problematic for people living under oppressive regimes, but you only have to look at the situations in Hungary, Turkey, USA, Malta, Poland etc to realise that 'democracies' can be captured and reverted to de facto autocracies if current populist trends continue

          1. Anonymous Coward
            Anonymous Coward

            Re: Ahh, old timers

            You see how all that open source technology actually helped authoritarian states to build a real surveillance states at a fraction of the costs and without developing most of the skills to build it? And not authoritarian states also, but the surveillance capitalism as well.

            Those who believed that the internet and open source would have created an utopia of good anarchism were utterly naive - they just helped to create the opposite. The populist trend as well has been tremendously helped by the same entities above.

            There's no software that can save the world - only people can. You have to build a system where you can trust you financial institution because any abuse will be punished, and the government has to be benevolent because otherwise you'll change it.

          2. katrinab Silver badge

            Re: Ahh, old timers

            Given that a load of previously-existing bitcoin exchanges have disappeared with customers' money; I'm not sure that "The problem with MasterCard is that it is regulated by the government" is a coherent argument. Governments are generally far from perfect and some are less perfect than others, but on balance, they are mostly better than no government at all.

          3. phuzz Silver badge
            Facepalm

            Re: Ahh, old timers

            If only there was some other way of moving money around. Perhaps one which relied on physical tokens which would be difficult or impossible for the government to track. Good thing we've got the blockchain for that though, because there's no way anyone could come up with anything similar.

            You could call it Computer Aided Special Holograms maybe?

            1. JimboSmith Silver badge

              Re: Ahh, old timers

              If only there was some other way of moving money around. Perhaps one which relied on physical tokens which would be difficult or impossible for the government to track. Good thing we've got the blockchain for that though, because there's no way anyone could come up with anything similar.

              You could call it Computer Aided Special Holograms maybe?

              During the Dot Com bubble my boss at the time went to a meeting at a startup. He wasn't going to go at all but there was another meeting nearby and he figured what the hell. It was a sort of loyalty system for websites where you gained a token for visiting a site. These tokens would then be exchangeable for something later on when you had enough. I think they described it as a digital version of Green Shield Stamps. My boss said he asked at the very start of the meeting what the minimum spend was to obtain a token. Well there wasn't one all you had to do was visit the site and from memory that was it. You could only get one token per day per site.

              He said he spent the rest of the meeting looking at emails on his BlackBerry hidden behind the literature he was given to read. He said they obviously hadn't considered the possibility that somebody might just set all the sites that offer tokens up as favourites/bookmarks. Then just open them once a day say when you started the computer. Also that didn't create loyalty as they may also sign up your competitor. They wanted companies to pay to be part of it with the minimum plus point for the company of extra traffic to the site. They wanted us to sign up and he said he'd put it to the board. That was his way of saying it wasn't going to happen.

            2. Anonymous Coward
              Anonymous Coward

              Re: My new cryptographic coin...

              Runs on sneakernet. To add to the cryptographic part, I'm physically using public/private keys in the form of paint colours.

        2. Brangdon

          Re: It is usually about 8 seconds,

          After 8 seconds you don't know for sure if you have the money. It might disappear again later. If you are in a hurry with Bitcoin and you don't care about whether you actually get the money, you can accept transactions with zero confirmations, or use the Lightning Network. Or switch to a currency like Nano that is designed for speed and gets sub-second transfers.

          A problem with MasterCard you missed is that they act as gate-keepers. They will refuse transactions to entities they disapprove of. This has included political organisations like WikiLeaks, porn merchants and the like. Some credit card companies won't let you use their card to buy Bitcoin. They are not a neutral intermediary. They have values which they impose on you.

      2. Snake

        Re: Ahh, old timers

        The problem with Bitcoin, and users seem in no hurry to fix it, is that in its current form it will NEVER be able to be used in everyday transactions; in its current form, users are more than happy to treat Bitcoin as an "investment", allowing it to float in value daily. This is a *failure* in terms of currency, just ask Venezuela: to function in an economy, as an actual "currency", the object in question must have a known value to all parties concerned.

        A "currency" that dramatically changes value daily, hourly actually, can never be used in transactions because no two people will be able to agree on how much value the trade will entail, once processing delays and fees are factored in. Therefore, using Bitcoin as currency is somewhat of a gambit, a leap of faith, that you'll actually get the value in the trade that you expected when you actually committed to said trade.

        That's no way to run an economy. Unless and until the day traders stop treating Bitcoin as a "investment", trading both long and short, and treat it as a "currency" that demands stability, even if said stability ruins their ability to play the Bitcoin markets, it can, and never will, be taken seriously.

        1. Claptrap314 Bronze badge

          Re: Ahh, old timers

          Not seen how the currency markets work, I take it?

          General stability is a huge plus (bordering on a necessity) for a true currency. But the reality is that there are certain investors that have made out like bandits by breaking currencies. Or the Bank of England. So the whole thing is a lot more nuanced than you are letting on.

          I'm no fan of coin. But that doesn't mean that I'm ignorant of the history of fiat, either.

          Fiat currencies are trivially subject to manipulation by the issuer--something that coin is largely invulnerable to (unless assuming you have enough miners). But all currencies are subject to speculation. A currency becomes stable as the speculators in it go broke. It's a beautifully circular problem.

          1. NeverMindTheBullocks

            Re: Ahh, old timers

            The currency markets aren't the problem here.

            In order to use Cryptocurrency to actually buy or sell things you have to have bought them with fiat currency at some point, unless you are in the fortunate position to have mined them yourself, but that puts you in the extreme minority.

            In the real world fiat currency, from an individual point of view, is very, very stable - Venezualan hyper inflation etc being edge cases. If you buy something for £X today then you should be able to buy the same thing for £X tomorrow, sales, discounts etc not withstanding. Real world prices are largely unaffected by the currency markets, and when they are the effects are minimal, a few percentage points either way at most and most of the time these fluctuations are absorbed by manufacturers and vendors in order to retain customers.

            If you buy cryptocurrency for £X today and then buy the same amount tomorrow, X is going to have a markedly different value and you will get a different quantity of cryptocurrency for your fiat currency. This means that the effective price you pay for a thing with Cryptocurrency will vary dramatically based on the fiat value of the cryptocurrency at the time you acquired it. This matters because in order to realize the value of your cryptocurrency you either have to convert it into tangible assets or back into fiat currency directly.

            If you buy £5000 of Bitcoins today and tomorrow you use that to buy Gold then there is a good chance you will get less gold for your Bitcoins than you would if you had just bought it with £5000 in fiat. Of course there is also a chance that you will get more than £5000 of gold, but that's the gamble with cryptocurrency, it's all speculation driven by a very volatile market that is open to manipulation by individuals or groups of individuals with the ability to execute very large transactions.

            Until the real world value of Cryptocoins against assets becomes protected from the speculative value and achieves real stability they will remain an investment tool rather than a day to day currency.

            1. katrinab Silver badge

              Re: Ahh, old timers

              And this stability means that you can sign a contract for £x per month, and you know where you stand. Nobody would sign a contract for x BTC per month.

              1. Toltec

                Re: Ahh, old timers

                A science fiction writer by the name of Jack Vance came up with a currency unit as follows-

                SLU or Standard Labour-value Unit

                The value of an hour of unskilled labour under standard conditions.

            2. Stork Bronze badge

              Re: Ahh, old timers

              Well explained, and this even without getting into transaction costs

    2. Anonymous Coward
      Anonymous Coward

      I sit in on a lot of blockchain/fintech pitches. These kids think they’ve just invented something, when all the bankers know we’ve been doing it since the Renaissance. The problems blockchain solves are not difficult, and blockchain solves them badly, and there have been better solutions already invented using just quills and abacuses.

      1. katrinab Silver badge

        A blockchain is just a way of storing information on a computer. It may well be superior to other file formats, but ultimately, it is just a file format, and if your USP is that you store business data in a particular file format, you don't have a business plan.

        Dear investors,

        I would like you to invest in my business. It is a courier service where the parcel tracking information is stored in a computer with anti-virus software installed on it. The funding will be by means of a pre-sale of postage stamps which you can use on my service. Anti-virus software is a huge and growing market, and this will cause the value of my postage stamps to increase in value many times over.

    3. vtcodger Silver badge

      All is for the best ...

      ... In this best of all possible worlds. What would they be doing if they weren't doing blockchain? Should we consider the possibility that wasting their time and money on pointless blockchaining is, in the overall scheme of things, an optimal use of their resources?

      1. katrinab Silver badge
        Mushroom

        Re: All is for the best ...

        Electricity requirements equivalent to a medium-sized country is not an optimal use of resources.

    4. Anonymous Coward
      Anonymous Coward

      I work for a company that pretends to use a blockchain and I can tell you that blockchain is a worthless technology

      I disagree, blockchain has its uses, but it is but one of the many tools we have in the IT toolbox - like clouds and other buzzwords, we're talking about technology that may be of use in some contexts, but not in others and it takes some expertise to work out where its use if appropriate.

      What I vehemently disagreed with was this trend where adding the word "blockchain" to a proposition magically attracted investment. I don't know what some investors were smoking, but I'm glad that that trend seems to be over although I know from experience that this only means that soon some idiot comes up with a new unicorn for them to chase after.

      As for crypto currency, I've been involved in some setups that were going to be yuge in crypto, and I had to leave. There's nothing more lethal to your reputation than to be associated with a combination of blatant incompetence, not enough aversion to money laundering and a complete disregard of reality that would maintain the assumption that institutional players would even consider touching this market without tight security, proper processes and good KYC/AML management in place.

      No thanks. I like my work, and I want to keep doing it for many more years. Getting involved in something that even has a whiff of crime associated with it is not in my plan.

  2. not_my_real_name

    Surely it makes more sense to create technology that monitors these public transactions than creating unenforceable legislation! Me thinks that banks be lobbying...

  3. tiggity Silver badge

    keeping the monopoly

    Money laundering operations are the province of various accountancy companies and banks. Can't have some upstarts who are "not part of the club" getting a slice of the laundering profits.

    Some of the top locations for money laundering / tax avoidance are UK related, be it exotic locations such as the BVI, or closer to home such as Jersey.

    If something was done about that festering cesspit first then people might think they are serious about whiffy transactions

    1. Anonymous Coward
      Anonymous Coward

      Re: keeping the monopoly

      Like or dislike it, at least that has some legislation and controls wrapped around it. If you've ever dealt with institutional finance at a decent level you'll find people who understand why KYC and AML exists and who get rightfully very uncomfortable in any discussion that would lower the barriers to crime.

      The coin outfits I have examined were *way* too open to subversion and takeover by the sort of people who presently seem to use real estate to launder their money.

  4. Doctor Syntax Silver badge

    These privacy coins the article mentions and the untraceable transactions. They sound very much like the bits of metal in my pocket and paper or plastic in my wallet, all bearing pictures of HMQ. Is the Treasury planning to outlaw them?

    1. DuncanLarge Bronze badge

      Exactly

      Thats exactly part of the argument the EFF made. The privacy coins help bring the benefits of physical currency to digital currency.

      I also remember years ago in the 90's reading about a plan to monitor the handling of banknotes using RFID chips. They also planned the same thing with books, hoping to help the book publishers stamp out secondhand bookshops.

      Both those plans seem to have died luckily.

    2. Velv Silver badge
      Headmaster

      Don't ask stupid questions, of course they would get rid of them if they could

      1. unimaginative
        Big Brother

        They intend to - all that talk about a cashless society.

        There is another motice to get rid of cash (apart from increased surveillance, that is). As long as people can keep physical cash central banks have limited ability to cut interest rates to below zero (because people will then just keep cash).

    3. vtcodger Silver badge

      Is the Treasury planning to outlaw them?

      Not that we're aware of. But India -- in an attempt to put a dent in its legendary corruption problems -- recently did something along that line. As I understand it, they effectively called in and reissued all their high value banknotes a couple of years ago at least theoretically generating a paper trail for most of the cash floating around the country. I'm skeptical that it really worked all that well, but it'd probably be nice if I was wrong about that.

      India is also considering making trafficing in cryptocurrency a felony. https://www.ibtimes.com/india-proposes-law-ban-cryptocurrencies-10-year-prison-term-users-2799371

      1. Primus Secundus Tertius Silver badge

        The UK called in all its high value banknotes during World War 2 to thwart the black market operators. For years the highest note in circulation was £5.

        1. Doctor Syntax Silver badge

          For many people then, and into the 1950s £5 was a high value note. Even 10 bob was serious money.

          1. Will Godfrey Silver badge
            Unhappy

            Reminds me of my (never to be forgotten) introduction to inflation. As a kid I was given 3 bob to go to the newsagents to get dad's tobacco and cig papers. That came to 2s/7d, giving me 5d for sweets. Then the price jumped up to 2s/9d ha'penny but dad still only gave me 3 shillings, leaving me only 2d ha'penny for sweets.

  5. Snowy Silver badge
    Flame

    Is this

    One of the reason some people are so set up on a no deal Briexit?

    1. Anonymous Coward
      Anonymous Coward

      Re: Is this

      Technically a no deal is simply having no agreed withdrawal agreement in place while the final and permanent deal is negotiated. The withdrawal agreement should only last a couple of years while its all hammered out but thanks to complete timewasters on BOTH sides the whole mess has been about the bloody withdrawal agreement and not about the final relationship which we could have all been working on since March the 29th had "May the Appeaser" not ruffled the feathers of parliament with a crappy agreement (treaty) and let us just leave deal or not and get on with it.

      Our businesses would have been happy knowing one way or the other also. But no, "May the Remainer" kicked the not so important can down the road just because she wanted to be ever so nice.

      1. Anonymous Coward
        Anonymous Coward

        Re: Is this

        If May was a remainer, we wouldn't be in this mess.

        She pretended to be one when she served under Cameron, but anyone who thinks she wanted to remain needs their head examined. The denial is great: it's all too easy to blame your lack of pink unicorns on something else when that something else is a scenario you've made up.

        The same thing will happen when/if brexit happens: when the country tanks, the denialists will blame the EU for sabotage (How does that work, I thought we were supposedly "much stronger" that the EU.), or they will blame the remainers, or they'll blame whatever the hell else pops into their heads.

        One things for sure, they won't agree to own the shit-storm they brew up.

        1. Doctor Syntax Silver badge

          Re: Is this

          "She pretended to be one when she served under Cameron"

          Quite. I'm sure that, like most people in Westminster she expected Remain to win & didn't want to end up on the wrong side. Her background in the HO would ensure that she would want to get as far away from the restraining influence of the EU as possible.

        2. Toltec

          Re: Is this

          "If May was a remainer, we wouldn't be in this mess."

          Is this one of those things where the right think the BBC is left biased and the left think it is right biased?

          Given she brokered a deal that was unacceptable to everyone I think she is something else entirely.

          1. Anonymous Coward
            Anonymous Coward

            Re: Is this

            Due to incompetence, arrogance, and the fact that we are not this great british empire that the whole world bows before, that "deal" was the best she could get.

            Typical leaver, blaming the fact that we couldn't get pink unicorns and fairy dust on the assumption "May must be a remainer".

            You voted Brexit. May at no time tried to stop brexit, and often shot down any remainers. She got a deal. Your lot could accept the deal or take no brexit, or delay (as you have) - NONE of the shit outcome is the fault of remainers. If you think Boris will get anything better from the EU, you're deluded.

            We already have/had a sweet deal compared to most countries, and leavers have squandered it.

      2. Teiwaz Silver badge

        Re: Is this

        What BOTH sides?

        There were THREE SIDES (at least) on propped up government to begin with

        Back bench tory MPs, May, and The DUP

        Turned the optimistic appraisal that each groups RED LINES could all be accommodated like picking your way judiciously through a maze was BOLLOCKS and it was actually a form of enTRENCHed warfare.

        It was a no win from the beginning. A stupid idea, egged on by the want of newspaper sales, badly thought out, poorly implemented and will need to be rescinded and begun again in a few years.

        Just like most government projects lately.

      3. unimaginative
        Unhappy

        Re: Is this

        The biggest problem for business is uncertainty. Remainer blocking of Brexit has caused more damage than the economic damage the remainers claim they are trying to prevent.

        1. Anonymous Coward
          Anonymous Coward

          Re: Is this

          Business leaders have a huge problem with the uncertainty, due to the hope we may not end up with the worst possible outcome. So simply letting the brexiters give us the worst possible outcome doesn't make them any better off at all.

          Anyway, sounds like Stockholm syndrome...

          Evil Villain: "There's no point struggling, or trying to escape, I'm still going to kill you"

          Reg user "unimaginative": Ok then [sits down]

          Everyone else: *struggle and try to escape, get caught, painfully*

          Evil villain: It's your fault, not mine that you are hurt now more than you'd otherwise be.

  6. Nick Kew Silver badge

    Traceable assets

    So untraceable bitcoin are a problem?

    Our government relies heavily on money-laundering. Both the country at large (see Prime London Houses) and the Tory party (see Private Eye's recent series on the man who owns them). If they can't go after highly-visible assets, how is invisibility a problem?

    Ultimately, software (open source or otherwise) facilitates money laundering on about the same level as the pub or coffee house where you go to discuss it.

  7. NullNix

    So... it appears that the authors of this document either didn't grasp that open source software is not a purely cryptocurrency thing, or expected it to be obvious that this stuff only relates to implementations of cryptocurrency software. In which case... it's still broken, since essentially all such software depends on generic layers: are the glibc maintainers going to be bound by this stuff? What about LLVM and GCC? What about the Linux kernel? Compromise that, you've compromised the cryptocurrency wallet stuff...

    (Never mind the obvious stupidity of trying to apply 'know your customer' regulations to something where the software is given away to anyone, so of necessity it would require both a time machine and telepathy to know even the simplest details about all future customers, let alone anything more -- not that open source developers can prevent some "customer" deemed unsuitable under the regulations from using the software anyway, since copyright licenses cover only distribution, not use, and if something is employed which does restrict use the software isn't open source any more.)

    What on earth were they thinking?!

    1. Will Godfrey Silver badge
      Unhappy

      This works better

      What on earth? Were they thinking?

      Ummm. No.

    2. phuzz Silver badge
      FAIL

      I think this is more likely to be a really poorly worded attempt to regulate crypto-currency software, than any crackdown on the likes of Apache (or Firefox, or Linux, etc.).

      Someone just didn't bother reading what they'd written, and didn't even notice that it could be taken to cover every piece of open source software.

      Hanlon's Razor should always be kept sharp.

    3. Doctor Syntax Silver badge

      "What on earth were they thinking?"

      Scope creep and over-reach.

  8. Walter Bishop Silver badge
    IT Angle

    Regulating the publication of open-source software?

    By any chance did any commercial software company help write this EU directive? This has to be the oddest juxtaposition of money laundering and Open Source software I've ever seen in the same document. I suspect that in relation to moving illicit revenue, this Directive will be as effective as a parachute made out of wet paper. Not a lot of people know this but both “Wall Street” and “The City” are exempt from reporting the movement of large amounts of money through their trading systems.

    1. Anonymous Coward
      Anonymous Coward

      Re: Regulating the publication of open-source software?

      Nice attempt to blame the EU. As with most things, it's the UK's intended implementation of the EU directive that's the issue.

      As always, whenever an EU directive comes into play, the UK expands it for its own gain, and then blames the EU if anyone complains. Both sides have been doing it for years, and the low IQ people of the UK have believed it.

      http://www.europarl.europa.eu/sides/getDoc.do?pubRef=-//EP//NONSGML+TC+P8-TC1-COD-2016-0208+0+DOC+PDF+V0//EN

      1. Anonymous Coward
        Anonymous Coward

        Re: Regulating the publication of open-source software?

        Good point - except the part where state that UK people have a low IQ.

        Bigoted statements like that show just how ignorant others in the EU can be.

        1. Doctor Syntax Silver badge

          Re: Regulating the publication of open-source software?

          Parsing error?

        2. Anonymous Coward
          Anonymous Coward

          Re: Regulating the publication of open-source software?

          I'm the anonymous coward you replied to.

          As a Brit, living in the UK, and fed up with vultures wanting to crash our economy, and idiots believing it's for their own good, I've tired of being diplomatic, and so I'll often sound blunt.

          However, when I wrote: "the low IQ people of the UK have believed it." I meant "the people in the UK (the ones who have a low IQ)", and not "the people in the UK (who all have a low IQ)"

          Gotta love the English language!

      2. Doctor Syntax Silver badge

        Re: Regulating the publication of open-source software?

        Interesting link. Particularly interesting in the the word "software" isn't mentioned at all.

        1. Anonymous Coward
          Anonymous Coward

          Re: Regulating the publication of open-source software?

          (Original AC here)

          I actually just repeated the link given in the article itself!

  9. This post has been deleted by its author

  10. Anonymous Coward
    Anonymous Coward

    "the fact that technology could be used to violate the law does not mean we should ban it"

    So any check or limitation on the sale and carrying of weapons should not exist? "Guns don't kill people, people kill people" etc. etc.?

    EFF & C. are pathetically naive - or worse. And I don't really believe people living in authoritarian states will be made freer by cryptocurrencies - authoritarian states usually have the means to put those controls EFF doesn't want in other states - and will even use them as a disruptive tool whenever they see an advantage (look at North Korea).

    Actually, when criminals can put you under treat, you're less free.

    1. Dan 55 Silver badge

      Re: "the fact that technology could be used to violate the law does not mean we should ban it"

      Actually, when criminals can put you under treat, you're less free.

      I've never liked Halloween, now I know why.

    2. Anonymous Coward
      Anonymous Coward

      Re: "the fact that technology could be used to violate the law does not mean we should ban it"

      Last I heard, money wasn't a weapon.

      A number of other things that can be used directly to kill people:

      swimming pools

      skipping ropes

      china pots

      ladders

      fists

      pianos dropped from a height. (happened a lot in 1920's America, going by the movies of the time!)

      Justin Biebers voice.

      etc.

      By your logic, these things should be more tightly regulated than cryptocurrencies!

  11. Anonymous Coward
    Anonymous Coward

    Wrong target

    If anyone in the cryptocurrency world needs regulating it's the cash for coin exchanges, given the rate at which these mismanage deposited funds and go bust with owners/employees running off with the assets, or keys controlling large assets being lost when a director unexpectedly dies abroad.

    As it is, their operations are a barely disguised accessory to money laundering. Without these exchanges, cryptocurrencies would lose their current use cases e.g. for illegal narcotics and weapon sales, and for collecting ransoms.

  12. Howard Hanek Bronze badge
    Childcatcher

    You Mean It's NOT Money Laundering?

    That's certainly a relief. I would think that money launderers would be begging for people to organize and front Bitcoin operations and run a gigantic Ponzi scheme at the same time.

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