Hi DeathAndTaxes,
We believe you are confusing two issues when it comes to FinCen. An MSB is a business like Western Union or Money Gram. No a MSB is what the regulations say an MSB is. You are accepting funds from a customer and transferring them to an exchange for a profit. That is a money transmitter. It is the very definition of money transmission. (5) Money transmitter —(i) In general. (A) A person that provides money transmission services. 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. “Any means” includes, but is not limited to, through a financial agency or institution; a Federal Reserve Bank or other facility of one or more Federal Reserve Banks, the Board of Governors of the Federal Reserve System, or both; an electronic funds transfer network; or an informal value transfer system; or
(B) Any other person engaged in the transfer of funds. Are you saying accepting USD from a client and transferring those USD at the direction of the client to an exchange is NOT money transmission? This is pretty cut and dry. The regulatory status of Bitcoin may be vague but USD to USD transactions are not. Then again i am just some guy so let me ask it another way. Do you have any statement by legal counsel or FinCEN (via administrative ruling) that the activity is not regulated as a MSB? They are trying to say this: If you are a bank you don't need to register as an MSB because you are an MSB and more. You have the licensing (under BSA) necessary to do these transactions and will be doing KYC/AML implicitly. I think you are misreading their posts, it's partially the language barrier on their part. |
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Videos of presentations? Doubt it, but here's for hoping.
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Have you (or is it your intent) to register with FinCEN as a Money Service Business?
If not do you intend to exclude US customers?
I thought [international] licensing was implicit in their relationship with a bank, no? If not this whole thing is a wash. Well the prospectus and business plan doesn't indicate they plan to. CFIG not the bank is the one engaged in the business of money transfer (accepting funds from clients and depositing those funds into the exchange's account). Right, but the bank is allowing them to be agents of their license it appears. That's my assumption. If I am wrong I will be very shocked, because even if they have the funds to get licenses, (as you know) it will be a year minimum before they can get approved. And that's if they are lucky. guess we just wait for them to clarify |
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Have you (or is it your intent) to register with FinCEN as a Money Service Business?
If not do you intend to exclude US customers?
I thought [international] licensing was implicit in their relationship with a bank, no? If not this whole thing is a wash. |
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Sorry, that wasn't clear. I've already started a dialogue with you outside the forum, but the question I asked (are you registered with the SEC) I would prefer a public response.
This question has been answered on the first page of our Prospectus, as it states the following: "Neither the Securities and Exchange Commission nor any state securities commission has approved or disapproved of these securities or determined if this prospectus is truthful or complete. Any representation to the contrary is false." Thank you, Crypto Financial Ah missed that, thanks. |
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To be clear, the reason I asked is because I want to start a dialogue with them. I assume they aren't and want to ask why. getitnow?
Dear jedunnigan, If you would like to have a dialogue with us please feel free to contact us at: contact@cryptofinancial.io or call us! The number is on our site. Thank you, Crypto Financial Sorry, that wasn't clear. I've already started a dialogue with you outside the forum, but the question I asked (are you registered with the SEC) I would prefer a public response. |
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Thank you for the response! I'm glad to hear that customer fees will be suppressed as much as possible. I also now have enough information to truly appreciate your amended dividend policy.
Thank you kleeck, We have had many discussions on and off the board with Investors and Potential Investors and we believe that our revised Dividends Policy is fair for everyone. Also we would like to thank the countless of Bitcoin supporters that have purchased our Shares so far since our IPO went public last Monday. Crypto Financial Are you registered with the SEC? Really? Just to clarify, you're asking if a company without a US presence, listed on a Canadian crypto currency exchange and accepting bitcoin investments from 'anonymous' participants is registered with the SEC? And if the answer were yes, would you view this as a positive aspect? Lol, perhaps you missed the entire thread. These guys are trying to be above-board, as is reflected in their [supposed] backing by a Panamanian bank. As an extension of this you would assume they are trying to run a legit operation, so it's only fair I ask. Or perhaps you would prefer me to just assume one way or the other. That always ends well. Regardless, what I think really shouldn't matter to you, as we should deduce our own judgments about these guys, so I'm curious as to why you really care what I think anyway? Not to mention you have no idea why I asked the question (as is very clear by your response) in the first place, so again, thanks for that worthless post! To be clear, the reason I asked is because I want to start a dialogue with them. I assume they aren't and want to ask why. +1 LOL |
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Thank you for the response! I'm glad to hear that customer fees will be suppressed as much as possible. I also now have enough information to truly appreciate your amended dividend policy.
Thank you kleeck, We have had many discussions on and off the board with Investors and Potential Investors and we believe that our revised Dividends Policy is fair for everyone. Also we would like to thank the countless of Bitcoin supporters that have purchased our Shares so far since our IPO went public last Monday. Crypto Financial Are you registered with the SEC? |
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Posted this on reddit, but it's relevant here as well:
Honestly people have been [relatively] positive about this move by Germany, but I don't think people understand the implications quite yet.
As I see it, this is an indirect attempt to put the brakes on a system of payment processing that has far lower fees then competing systems (credit cards) and is therefore a threat to their survival. This tax heavily favors traditional payment mechanisms (Bitcoin's no-tranaction fee just went out the window), no question. That or Germany is afraid to call it a currency as such, in fear of providing too much legitimacy to the protocol, thus they stuffed it in the only other bucket it could be seen fitting: commodity (aka unit of account). This is why new legislation must be written, simply because it doesn't fit anywhere else... all preexisting laws reduce its accessibility/attractiveness on some level.
There is always the possibilities that they don't completely understand the repercussions of such a ruling, but I doubt it.
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Here i am speaking to the hard work mike has put in making bitcoinj possible. You'd do well to remember that. Thanks .. maybe I will. Deifying devs and calling people dicks is probably not going to make me listen to you much though ... I wonder how he missed that random number generator Android bug for soooo long? Maybe concentrating on the law enforcement possibilities for bitcoinJ was occupying too much of his dev mind share? lol deify? boy oh boy i love leaps in logic. But sure thing mate, you're the boss. I'll stop defending someone who has dedicated their time to meaningful development in the bitcoin space and start throwing baseless accusations around that even if they were true, wouldn't fly in practice. Happy now? What I can tell you is I'm definitely over this OT convo tho, thanks for the insights. To make this post worthwhile: Self-hosting your own mail server is a short term solution for long term problem. e-mail must be retired because of usability and security problems. Just like BBS or Gopher is no longer used by mainstream.
I agree to an extent, although it will be ages before email is phased out. An easy-to-use alternative will have to be made accessible first. |
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The fact that Mailpile consists of a google developer already makes me nervous to use Mailpile.  The fact that Bitcoin consists of a google developer already makes me nervous to use Bitcoin. you've got to be kidding. If any changes are made the community disapproves of we won't update our clients, simple as that. Mike Hearn is a legend mate don't be a dick. ... he's not a legend ... bitcoin is the trust no-one currency, you'd do well to remember that. If you read my post, it's not about trust in Mike. He has done a TON for this community. Trust comes in when you update the client, so you peruse the changes and see if they are up to standard. You trust the code, not the people. Here i am speaking to the hard work mike has put in making bitcoinj possible. You'd do well to remember that. |
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The fact that Mailpile consists of a google developer already makes me nervous to use Mailpile. The fact that Bitcoin consists of a google developer already makes me nervous to use Bitcoin. you've got to be kidding. If any changes are made the community disapproves of we won't update our clients, simple as that. Mike Hearn is a legend mate don't be a dick. |
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I think going about this whole shutdown thing publicly was prudent on the part of Lavabit's founder. He has quite a bit of exposure and it would be very bad for PR if LE took him down at this point.
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They are swiss based. Have you seen Switzerland's privacy laws? no good mate  If you aren't looking to use GPG there are very few (if any) mail providers that can promise to keep your emails safe. Depends on what you are looking for, really. |
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Looks like some whale was convinced: they have now attracted an additional 6k BTC.
They probably got all excited while reading -REDACTED- under section -REDACTED- about how the -REDACTED-, which means the company will -REDACTED- both now and after -REDACTED- comes to fruition! As you can see, everyone wins!  Would you be willing to audit them? Put --redacted-- to rest? I trust you, as do others here. Yes and no. Yes, I would be willing to do so, but they're not willing to let me. I've been in discussions off the board on this, and it sort of comes down to them not seeing the point in revealing the details to random people from "a forum" (even with a signed NDA) ...which is ironic in a way, considering it's the 'random people' they're trying to sway to fund them. On the other hand, no, I'm not entirely sure I'd go above and beyond for them...and this also stems back to the off-forum discussions. They have groups of auditors already (or so I've been told), and I'd expect professional consultants to be vastly more thorough and knowledgeable when presented with full details. Anyway, congrats on the whales jumping on board with this one. It's clear they know something that wasn't disclosed here. At this point this sort of investment just isn't for me; too many 'unknowns' and the risk/reward ratio seems a bit construed. Not to mention if you're a business with a $10m investment held solely for licensing, something tells me you don't have to go pandering on the internet to secure another $3m to cover startup costs. From a business standpoint that doesn't make much sense, and in the end it just doesn't sit right with me. Ah, so they aren't being true to their word? That's disappointing. In that case I understand your sentiment. |
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So the reason you've only raised (at the time of writing) 1.7% of your total goal is just because your Business Plan is too long? Don't you think that's a bit...naive?
Looks like some whale was convinced: they have now attracted an additional 6k BTC. They probably got all excited while reading -REDACTED- under section -REDACTED- about how the -REDACTED-, which means the company will -REDACTED- both now and after -REDACTED- comes to fruition! As you can see, everyone wins! Would you be willing to audit them? Put --redacted-- to rest? I trust you, as do others here. |
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Yes. Note: Facebook will still log all the messages, and because it is OTR the encryption is fairly weak... even if the keys constantly change. Obviously the plausible deniability/log tampering argument might hold up in a court room, but please don't say anything on that platform you wouldn't want Facebook or LEA reading. |
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Given that you have to use someone's key to encrypt a message, it would be safe to assume they had software to generate and handle said key.
But how would you know if they have a key in the first place? You'd have to negotiate that beforehand. Isn't there something like OTR but for email?
With a diffie-heilman agreement specifically? Or are you talking about GPG/PGP? I mean something where the two ends negotiate an encryption over unsecure lines in a secure manner; while providing the option to fall back to plain text if the other side refuses to go secure. Yea for email GPG/PGP. For IM OTR, for VOIP ZRTP. With GPG/PGP the email client has no clue whether the receiver has or hasn't means to read encrypted data until the user tells it... Okay I see what you mean. Unfortunately building a system like you mentioned requires a 'failsafe' for decrypting the messege then sending plaintext if encrypted message can't be decrypted by the receiving party, an inherently insecure action. OTR cannot do this either, so curious as to why you 'said similar to OTR for email' but then responded as you did? Last i checked (not recently) OTR did indeed allow you the option of using plain-text if the other party didn't had OTR Disabling your OTR or telling it to resort to plaintext if encryption is not available is a feature, yes. In the latter scenario OTR first sends a key message, and if they get no response the user can decide what the default option is (retry key exchange or send plaintext). This is dependent on immediate communication between the two recipients. This would only be possible via email if the person sending the email sent it encrypted, then got a response from the recipient that they don't accept said encryption and then a plain text message will be sent. If you mean can the user send two messages at once, one encrypted, the other not, both in one larger encrypted container, the outter shell of which can be decrypted by the recipient without a special plugin and not seen by an attacker... I don't know if that is possible. |
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This should be good ... he may come across sometimes like a big, funny guy (clownish) but you know what? ... He just goes ahead and does shit, he doesn't just talk about it. Yea there is no doubt he is a doer more than a talker, but don't walk into his playpen willy nilly. If you are looking for secure encrypted mail storage the only person you can trust is yourself. Using open source software or at least auditable services is key. |
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Given that you have to use someone's key to encrypt a message, it would be safe to assume they had software to generate and handle said key.
But how would you know if they have a key in the first place? You'd have to negotiate that beforehand. Isn't there something like OTR but for email?
With a diffie-heilman agreement specifically? Or are you talking about GPG/PGP? I mean something where the two ends negotiate an encryption over unsecure lines in a secure manner; while providing the option to fall back to plain text if the other side refuses to go secure. Yea for email GPG/PGP. For IM OTR, for VOIP ZRTP. With GPG/PGP the email client has no clue whether the receiver has or hasn't means to read encrypted data until the user tells it... Okay I see what you mean. Unfortunately building a system like you mentioned requires a 'failsafe' for decrypting the messege then sending plaintext if encrypted message can't be decrypted by the receiving party, an inherently insecure action. OTR cannot do this either, so curious as to why you 'said similar to OTR for email' but then responded as you did? |
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