As bitcoin soars, so do ransomware attacks. Is it time to 'stop the madness?'
In Conversation: It's a bad time for hospitals to be under attack. Can (and should) cryptocurrency be stopped?
Bitcoin is back, soaring 150% in 2020, and on Wednesday reached heights it hadn’t vbseen since 2017. Of course, if you dealt with a ransomware gang in the past three years, you know Bitcoin never left.
You might have missed the news recently, overshadowed as it was by the presidential election, but you should know: An unprecedented wave of ransomware attacks against hospitals has come at the worst possible time. Already struggling to keep up with the second wave of coronavirus infections, medical facilities around the U.S. were warned recently by the FBI about "credible information of an increased and imminent cybercrime threat to U.S. hospitals and healthcare providers."
It was a thunderously-loud alarm bell. Cybersecurity firms reacted with equally ominous warnings.
"I can't think of any (cyberattacks) that rivals this in terms of danger to the public," FireEye's John Hultquist told Wired.
The Associated Press reported that at least five U.S. hospitals were hit by the Ryuk ransomware just days before the U.S. election, and security experts warned hundreds more could be teed up for such an attack.
Recent attacks show how successful ransomware gangs have been at this lately. In September, all 250 U.S. facilities of the hospital chain Universal Health Services were hit by ransomware causing procedures to be delayed or patients to be transferred to other facilities.
Alex Holden, CEO of Hold Security, told AP that his firm has tracked discussion of plans to attack more than 400 hospitals in the coming weeks. He also said the Russian-speaking group behind the ransomware was demanding $10 million or more to restore hospitals' systems.
Which brings me to Bitcoin and other cryptocurrencies. The vast majority of ransomware gangs demand payment via cryptocurrency, which they favor for its anonymity and the way it enables cross-border payments. Since global law enforcement authorities seem powerless to stop the crypto crime gangs, is it time to stop the crypto?
For today's In Conversation about this controversial topic, here's cybersecurity consultant John Reed Stark, along with Duke professors Lee Reiners, David Hoffman, and Shane Stansbury.
(If you are new to In Conversation, I am a visiting scholar at Duke University this year studying technology and ethics issues. These email dialogs are part of my research. See all the In Conversation dialogs here.)
To: John, Lee, Shane, and David
Cryptocurrency and the blockchain technology behind it inspire some of the most heated arguments you'll find anywhere. So I don't delve into this topic lightly, but it seems the question should be asked: If cryptocurrency is the main tool enabling ransomware, and we can't stop the criminals, can we stop the Bitcoin? Is it time to consider doing something drastic? What would that look like? Jamie Dimon rather famously said Bitcoin was only good for fraud anyway.
To: Bob, David, John
While I personally wouldn’t shed a tear if Bitcoin and other cryptocurrencies were “banned”, the idea strikes me as unfeasible for several reasons.
First, what exactly would you ban? Bitcoin only exists as computer code and is transmitted with code. The blockchain technology that powers bitcoin ensures that every single computer (node) running the Bitcoin software maintains the exact same copy of the ledger that contains the record of every single Bitcoin transaction. While the Computer Fraud and Abuse Act (CFAA) makes it illegal for anyone to distribute computer code or place it in the stream of commerce if they intend to cause either damage or economic loss, there are clearly many individuals who are running full Bitcoin nodes with no such malicious intent. Furthermore, the courts have traditionally held that the mere possession of code, even if harmful, is speech protected under the First Amendment.
The more realistic strategy would be to prohibit the conversion of cryptocurrency into fiat currency. Right now, ransomware attackers and other malicious actors rely on the ability to convert their ill-gotten cryptocurrency into fiat currency. Absent such ability, the incentive to conduct ransomware attacks severely declines. Implementing this strategy in the U.S. would require Congress to enact legislation that prohibits the operation of cryptocurrency exchanges. But even if Congress does this, there will still be other countries that permit cryptocurrency exchanges; and many of these exchanges require minimal customer verification. Because cryptocurrency is borderless, malicious actors will simply rely on overseas exchanges to convert their “ransom” into fiat currency.
I also see no evidence that policymakers would ever consider banning cryptocurrency or cryptocurrency exchanges. There are over twenty members in the Congressional Blockchain Caucus who “have decided on a hands-off regulatory approach, believing that this technology will best evolve the same way the internet did; on its own”; the ranking member of the House Financial Services Committee, Patrick McHenry R-NC, once tweeted: “The world that Satoshi Nakamoto envisioned, and others are building, is an unstoppable force. As policymakers, we should not attempt to deter this technology, but instead ask ourselves: what are we doing to meet the challenges & opportunities of this new world of innovation?”; and current Georgia Senator, Kelly Loeffler, was previously CEO of Bakkt, a digital asset custody company.
It is a mistake to think that cryptocurrency operates on the fringes of our economy and is principally the domain of techno-libertarians and malicious cyber actors. Prominent Silicon Valley venture capital funds are heavily invested in cryptocurrency, there are regulated cryptocurrency futures contracts that anyone with a TD Ameritrade account can trade, and the acting Comptroller of the Currency was previous general counsel at cryptocurrency exchange Coinbase. Any Congressional action that prohibits the possession or trading of cryptocurrency would destroy a tremendous amount of wealth in the real economy.
Like it or not, the genie is out of the bottle. The best we can do now is work with other countries to develop global standards that restrict the ability of malicious actors to exchange cryptocurrency into fiat currency. And if cryptocurrency ever becomes a legitimate medium of exchange – God help us.
To: Lee, Shane, Bob
Lee, I tend to agree that an outright ban is not feasible. I also wonder if we need to fully restrict the exchange of cryptocurrencies for fiat currency or whether we just need to require some level of provision of identity of the individuals who are involved in the transaction. I am not an expert in anti-money laundering efforts, but I wonder if there are lessons to be learned there.
I agree that it is unlikely that the US will be able to convince all countries to coordinate around providing the identity of individuals who are converting cryptocurrencies, but perhaps pushing anonymous conversion of cryptocurrency to a small minority of countries would provide value. For example, it could assist national security and law enforcement agencies by reducing the investigatory space for combating ransomware attacks and thereby increasing the value of standard cyber-surveillance tools to determine who is doing business in these non-compliant jurisdictions. Most developed countries should share a desire to protect their hospitals, schools and critical infrastructure operators from ransomware attackers. It seems doable that many countries should be able to come together to put controls on the types of anonymous conversions to fiat currency that currently fuel the plague of ransomware attacks.
To: Lee, David, Bob, and John
Have you all seen the TV series “Deadwood”? If you haven’t, do yourself a favor. Get an HBO trial subscription and stream it. It’s worth your time. The series follows the evolution of a frontier town in South Dakota during the gold rush as it navigates its way toward a functioning, civilized society. We witness its residents grapple with fundamental questions like: To what extent are we willing to trade some of our freedoms for law and order? What about a government? How much oversight do we actually need? Do we really need a mayor? And how about money? Should we place our faith in a paper currency as a substitute for gold? Do we really need a bank?
When I think of cryptocurrencies, I think of Deadwood. (More precisely, I think we are in the equivalent of Season Two.) These new “currencies” have caused us to ask some of those same fundamental questions. What exactly are the trade-offs we are willing to make in adopting these products? To what extent are the benefits of cryptocurrencies, such as autonomy and accessibility, outweighed by the societal costs? I’m willing to keep an open mind, but from what I’ve seen, the downsides are piling up. And one of the biggest problems is that the very characteristics that make cryptocurrencies attractive, such as (relative) anonymity, also make them the perfect tool for criminal activity, with ransomware being a prime example. That’s a problem.
So should we ban cryptocurrencies? I tend to agree with Lee and David that we’re probably too far down the road for that. I do like the idea of focusing on the point of exchange. At least in their current state, cryptocurrencies are only as valuable as the fiat currencies to which they can be converted. At some point, just as a drug trafficker is going to want to convert his dirty proceeds to usable dollars (or the equivalent), a bad actor collecting cryptocurrency is eventually going to want to trade his proceeds for cash. I’m all for greater disclosure and transparency at these points of exchange, but then again I’m a devoted institutionalist who appreciates the value of a centralized banking system.
I’m eager to see how we decide to strike this balance. Unlike Deadwood, I have a feeling that it will take us more than three seasons to bring this saga to a close. Although (spoiler alert), like the series, I suspect that not everyone will be satisfied with the ending.
To: Shane, David, Lee, Bob
Great stuff Shane!!!
I love the Deadwood analogy (and the show – one of my all-time favorites). To me, I see a similar analogy in the celebrated John Wick thriller films, where John Wick, is an international assassin who frequents the Continental, a hotel that functions as neutral territory for hired cutthroats and murderers.
To serve its criminal clientele, the Continental Hotel uses its own uniquely branded gold coins as currency. All services in the Continental are paid by the coins including weapons and munitions supply (from the Continental’s Sommelier) or body armor (from the Continental’s seamstress). All the criminals Wick encounters seem to accept the coins – which can pay off expenses ranging from a bar tab to an invoice from the contractor Wick hires to dispose of the typically 20-30 bodies he leaves behind after a particularly deadly negotiation or dispute.
Only a few years ago, the Continental’s coin-based barter exchange may have seemed limited to the imaginary universe of Hollywood blockbusters -- but the Continental’s in-house currency system and the John Wick economy are no longer fiction -- and are now happening right in our midst.
(If this post is truncated, you can keep reading it at http://redtape.substack.com/p/conversationtimetostopbitcoin)
Lee and David are correct, the bad news is that the train has left the station and an outright ban faces extraordinary practical hurdles. But the good news is that there already exists a litany of laws on the books that could significantly curtail Bitcoin’s expansion and stop the madness. Lee’s and David’s point about conversion firms and AML is particularly salient here. Perhaps using the laws on the books could put a chokehold on Bitcoin abuses (at least here in the U.S.), and more importantly, could stifle Bitcoin’s alarming and disquieting expansion into legitimate business circles.
First off, to me, Bitcoin is nothing more than computer-generated chattel which dwells amid a sinister and underground economic realm of competing bandits. Consider Bitcoin’s most notorious use: money laundering, ransomware, terrorism, illicit drug, gun and child pornography sales and the list goes on. That is why, ironically, one of Bitcoin’s most convenient criminal attributes is its use for the theft of other Bitcoin. By elevating Bitcoin profiteering into a core businesses line, Silicon Valley venture cryptocurrency futures peddlers and especially the acting Comptroller of the Currency (who Lee points out was the previous general counsel at cryptocurrency exchange Coinbase) are not only facilitating a new brand of corporate harm, but also presenting a rather poor example of corporate ESG (environmental and social governance) to say the least.
Consider also Bitcoin's unregulated marketplace, replete with: rampant manipulation; wild price volatility; pervasive cybersecurity vulnerabilities; hidden tax and capital gain burdens; and a litany of other entanglement mishaps. Bitcoin’s anarchistic valuations remain generally unregulated and without any meaningful oversight, leaving them easily susceptible to fraud and chicanery by insiders, management and better-informed traders and market participants.
Politicians from Both Sides of the Aisle Agree: Bitcoin is Bad
There exists a significant amount of common outrage regarding Bitcoin coming from both sides of the political aisle. President Trump, despite some members of his administration, is loudly anti-crypto, as evidenced by a July 2019 tweet in which he stated “I am not a fan of Bitcoin and other Cryptocurrencies, which are not money, and whose value is highly volatile and based on thin air. Unregulated Crypto Assets can facilitate unlawful behavior, including drug trade and other illegal activity . . .” His position oddly aligned him most closely with an array of loud and active cryptocurrency critics and skeptics, who also happen to be some of the most virulent anti-Trump Democrats, including U.S. Congresswoman Maxine Waters (D.Ca); U.S. Senator Elizabeth Warren (D Mass.); and U.S. Congressman Brad Sherman (D.Ca.). So there remains quite a bit of anti-crypto sentiment in Congress and (at least for now) in the White House.
Along the same lines, on July 10, 2019, at a congressional committee, Federal Reserve Chairman Jerome Powell raised concerns about cryptocurrencies, especially Facebook’s proposed Libra cryptocurrency, stating:
“Libra raises serious concerns regarding privacy, money laundering, consumer protection, financial stability . . . These are concerns that should be thoroughly and publicly addressed.”
The top Democrat on the Senate Banking Committee, Sherrod Brown of Ohio, echoed Chairman Powell’s alarms, sending a July 10, 2019 letter on to Mr. Powell and others at the Federal Reserve, asking the central bank to protect consumers and the economy from “Facebook’s Monopoly Money,” stating:
“We cannot allow giant companies to assert their power over critical public infrastructure. The largest banks and the largest tech companies do not act in the interest of working Americans, but in the interest of themselves and their investors. The Fed must take a proactive role to ensure that the payments system remains accountable to the public.”
A few days later, on July 15, 2019, U.S. Treasury Secretary Steven Mnuchin joined the fray, stating that he had “very serious concerns” about cryptocurrencies going so far as to classify cryptocurrencies as “a national security threat” because of their use to fund illicit activities. Secretary Mnuchin explained:
"This is indeed a national security issue . . . Cryptocurrencies such as Bitcoin have been exploited to support billions of dollars of illicit activity like cyber-crime, tax evasion, extortion, ransomware, illicit drugs, and human trafficking . . .”
My guess is that this outrage will grow exponentially given the increasing economic damage and soon-to-be increasing actual fatalities from Bitcoin’s evils, such as deaths from hospital ransomware attacks and Bitcoin-funded terrorists. Just ask Baltimore, Florida, Dallas and the many other hospitals, municipalities and corporations who have paid ransomware demands over the past few years. To them, and to so many other victims, the mounting menace of cryptocurrency is not a matter of economic liberalism or financial freedom, it is a matter of life and death.
So how to stop it all?
Lee and David are right to focus on intermediaries -- and the tone would need to start at the top. The President could kick off a war against Bitcoin from the federal government by creating a national task force and orchestrating a federal cryptocurrency sweep, using gatekeeper theory (discussed in more detail below) to focus prosecutorial and regulatory efforts on the many cryptocurrency financial platforms, custodians and other intermediaries who control “access” to cryptocurrency markets. In other words, by taking on the conduits and go-betweens that cryptocurrency users pay to trade and convert the cryptocurrency obtained from their extortion schemes, murder plots and other nefarious activities, the federal government could have a dramatic impact upon the cryptocurrency marketplace.
Commentators lament that the U.S. financial regulatory structure was not designed to tackle the technical complexities of cryptocurrency, harping on the disfunction and chaos created when no single federal agency wields comprehensive authority over its many varying elements. However, what these commentators are missing is that cryptocurrency's jurisdictional maze and lack of precedent is actually a strength, not a weakness.
Indeed, despite the fragmented and splintered regulation of cryptocurrency, the government still enjoys a mammoth armada of applicable administrative and law enforcement personnel, providing potent resources for a proposed federal crypto-offensive.
Aside from the obvious litany of federal agencies who prosecute fraud, and enjoy traditional jurisdiction over cryptocurrency marketplace, some prosecutorial and regulatory agencies can even take action in the absence of fraud, charging cryptocurrency market intermediaries for operating without lawful compliance, protections and licensure in place. These include:
Criminal prosecutorial agencies like the U.S. Department of Justice (DOJ);
Civil enforcement agencies like the U.S. Securities and Exchange Commission (SEC) and U.S. Commodity Futures Trading Commission (CFTC); and
Financial regulatory agencies like the U.S. Treasury Department and its incumbent Financial Crime Enforcement Network (FinCEN), Office of Foreign Assets Control (OFAC), and Internal Revenue Service (IRS).
Each of the above storied, capable and proven agencies can expend their vast jurisdictional reach to investigate and prosecute crypto-related crimes, by enforcing a mix of the licensure-related statutory weaponry of existing laws, rules and regulations already on the books.
In other words, even though the government can’t prove that an unsafe and dangerous car has been involved in a hit-and-run, the government still has the tools to take that car off the road.
For starters, the federal government should steal a page from the playbook of perhaps the most famous and successful SEC enforcement director in history: The Honorable Stanley Sporkin. Director of the SEC Enforcement Division from 1974 to 1981; general counsel to the Central Intelligence Agency from 1981 to 1986; and U.S. District Court Judge for the District of Columbia from 1985 to 2000.
Judge Sporkin championed the principle of what has come to be known as “gatekeeper liability,” premised upon what he referred to as the “access theory” of regulation and enforcement. Judge Sporkin’s decree: Instead of pursuing every bad actor, opt instead to achieve better, faster and more effective results in the long run by pursuing those who control “access” to our capital markets. Judge Sporkin’s concept of gatekeeper enforcement leverages varying resources while also packing the most powerful punch.
In the cryptocurrency marketplace, the most obvious targets for a gatekeeper assault include:
Cryptocurrency platforms (including so-called cryptocurrency exchanges) who allow for the conversion of Bitcoin and other cryptocurrencies into dollars;
Crypto-custodial services who provide digital wallet and other storage solutions for customers to safeguard and warehouse their cryptocurrency; and
Corporate crypto-facilitators, who manage crypto-transactions for retailors and other companies seeking to accept cryptocurrency as payment for goods or services.
The best reason for gatekeeper theory? In stark contrast to the hackers and other cyber-criminals who go to extreme efforts to conceal their identities, crypto-gatekeepers actually want to be found.
Crypto-intermediaries market their services aggressively, especially online and via social media. Moreover, the Internet renders crypto-intermediary culprits easier to surveil, easier to track, and ultimately, easier to catch. This may yet prove to be the most profound change brought by the Internet on the field of law enforcement and financial regulation. Far from tying the hands of investigators and prosecutors, the Internet has evolved into the virtual rope that crypto-gatekeepers may use to hang themselves.
DOJ seems especially well-suited to use gatekeeper theory to curtail Bitcoin’s expansion and wipe out its criminal use. Failure to comply with U.S. regulations involving and adjacent to cryptocurrencies can result in federal criminal charges. The DOJ can use not only on the traditional criminal money laundering statute (18 U.S.C. §§1956 and 1957), but also on the operation of unlicensed money transmitting businesses (18 U.S.C. §1960), and the Bank Secrecy Act (31. U.S.C. §5331 et seq.). In addition, the DOJ can criminally prosecute leads generated by a broad range of federal and state regulators, including most importantly FinCEN, OFAC, SEC and IRS (who already have robust, effective and proven DOJ liaison programs)
As indicated in the newly released DOJ Cryptocurrency Enforcement Framework, DOJ enjoys broad jurisdiction in order to combat what it views as cryptocurrency’s substantial role in serious criminal activity. Potential federal criminal charges may stem from:
statutes prohibiting wire fraud, mail fraud, and securities fraud;
statutes criminalizing tax fraud;
statutes criminalizing identity theft/identity fraud;
money laundering and AML statutes;
operation of an unlicensed money transmitting business.
DOJ’s reach applies to many participants in the cryptocurrency ecosystem, including trading platforms, crypto kiosks, money service businesses, virtual currency casinos, custodial and digital wallet providers, etc. DOJ can prosecute each for failure of their firms to safeguard customer data and failure to stop their wares from exploitation by illicit actors like terrorists and other money launderers.
FinCEN’s AML requirements combined with state law MSB licensing and bonding requirements create a hefty, burdensome and onerous federal and state regulatory burden and concern for crypto-intermediaries. Thus, when a cryptocurrency intermediary conducts business with suspicious individuals, their actions could raise AML red flags and violate FinCEN’s Guidance on the Application of FinCEN's Regulations to Persons Administering, Exchanging, or Using Virtual Currencies.
A “federal cryptocurrency sweep” could direct that cryptocurrency firms be subject to on-site audits and scrutiny of individual transaction activity for AML compliance, which in turn could lead to institutional and management civil liability, penalties, fines, license revocation — even potential criminal exposure for individuals caught intentionally circumventing AML obligations.
Given the identification and verification challenges associated with the global locations, pseudo-anonymity, encryption, decentralization and historically criminal tendencies of typical cryptocurrency users, a federal sweep of cryptocurrency intermediaries will likely identify a plethora of AML, KYC and other BSA violations. Not only do cryptocurrency firms typically lack the sophisticated technological compliance infrastructure of traditional U.S. financial institutions, but they are also often severely misguided when it comes to their AML/KYC and other related BSA compliance responsibilities.
Along the same lines, federal and state prosecutors and regulators also enjoy a lesser known (and oft misunderstood) jurisdictional “hook” when cryptocurrency intermediaries run afoul with state registration of so-called money transmitters.
A subset of the larger group of MSBs, a money transmitter is typically defined to include a person that “provides money transmission services, or any other person engaged in the transfer of funds.” The term “money transmission services” means “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.”
Failure to register as a money transmitter in a state can, under certain conditions, trigger DOJ criminal prosecutorial jurisdiction. Pursuant to 18 US Code §1960, captioned Prohibition of Unlicensed Money Transmitting Businesses: “Whoever knowingly conducts, controls, manages, supervises, directs, or owns all or part of an unlicensed money transmitting business, shall be fined in accordance with this title or imprisoned not more than 5 years, or both.”
Section 1960 lists three categories of unlicensed money transmitting businesses, which are, in summary:
Those operating in a state that requires that business to be licensed and makes it a misdemeanor or felony not to do so;
Those that fail to comply with Treasury Department regulations covering such a business (e.g., registering with FinCEN); and
Those that transmit money known to the transmitter to come from or intended to finance criminal activity.
In most instances, Section 1960 does not require specific intent.As part of the USA Patriot Act, Congress amended Section 1960(b)(1)(A) to provide that a defendant can be convicted of operating an unlicensed money transmitting business “whether or not the defendant knew that the operation was required to be licensed or that the operation was so punishable.” This strict liability paradigm is a formidable contrivance for investigators and prosecutors, who can allege liability regardless of the intent or mental state of the perpetrator. (Many drug possession crimes and statutory rape are examples of other strict liability crimes.)
Similarly, Aside from AML and KYC requirements, the U.S. Treasury’s Office of Foreign Assets Control (OFAC) also requires cryptocurrency financial intermediaries to conduct specific verification processes for offshore taxpayers. For crypto-gatekeepers like cryptocurrency firms, meeting their AML, KYC and OFAC responsibilities is a Herculean task, making charging decisions easier and providing endless prosecutorial fodder.
In addition to prosecuting cryptocurrency firms with AML, KYC and OFAC violations, Congress could add resources to the SEC’s already active cryptocurrency enforcement program, allowing the SEC to redouble their efforts applying gatekeeper theory. The SEC has already been hard at work bringing a slew of enforcement actions addressing the often bold and transparent violation of critical SEC registration requirements by cryptocurrency firms.
By way of background, most cryptocurrency financial marketplaces, platforms and intermediaries mistakenly believe that the SEC’s exchange-related and brokerage-related licensing requirements do not apply to them. Thus, most:
Are not registered with any federal government agency and would argue that they have no federal liquidity, net capital or other depository or financial requirements of any kind;
Are not examined or audited by any federal agency such as the Federal Reserve or the U.S. Securities and Exchange Commission (SEC); and
Are not examined or audited by any quasi-government agency such as the Financial Industry Regulatory Authority (FINRA).
Digital wallets and other crypto-custodial services are another area ripe for government intervention. With the increasing popularity of investing in Bitcoin and other cryptocurrencies, digital wallets have become a common custodial service offered by an array of cryptocurrency intermediaries. Though Bitcoin and ether might not be classified as securities, by targeting digital wallet services for SEC registration violations, the government could significantly impact the cryptocurrency marketplace, potentially crippling an important access point of cryptocurrency users.
The Internal Revenue Service could also pile-on and achieve similar results by policing crypto-related tax violations. Cryptocurrency investors are typically extremely active traders and when a U.S. taxpayer has bought and sold Bitcoin for a profit, a failure to pay the tax on that gain could be unlawful. By issuing subpoenas to cryptocurrency platforms and other cryptocurrency gatekeepers regarding cryptocurrency transactions, the IRS can identify tax-delinquent U.S. taxpayers and disrupt the entire cryptocurrency marketplace. Indeed, over the past few years, the IRS has issued subpoenas to several crypto trading platforms, ordering them to disclose details about user accounts.
For example, in 2018, Coinbase had to disclose approximately 13,000 user accounts including taxpayer identification number, name, birth date, address, records of account activity, transaction logs and all periodic statements of account or invoices (or the equivalent) pursuant to John Doe summons’. Moreover, starting 2020 tax season, on Schedule 1, every taxpayer has to answer at any time during the year receipt, sale, sending, exchange, or otherwise acquiring any financial interest in any virtual currency.
In a Nutshell
By creating a nationwide federal and state government task force to stop crypto-related crime by mobilizing an already empowered, active and capable army of federal and state law enforcement and regulatory agencies together for a national gate-keeper crackdown, the tide of Bitcoin could turn. The SEC has already accomplished this kind of success by wiping out initial coin offerings and similar related nonsense from legitimate financial circles, despite the opposition from some very powerful law firms and other vociferous factions. In fact, the SEC’s crackdown was like shooting fish in a barrel. Why not take a shot at achieving the same success with crypto – there is so much to gain and so very little to lose.