Why do ransomware gangs like bitcoin? It's the censorship resistance

A new type of crime has recently emerged: big-ticket repeatable ransomware. Bitcoin is the chosen payments method for ransomware gangs. But these gangs don't use bitcoin because it is anonymous. They've chosen it because it is censorship-resistant.

Here's a quick illustration of how ransomware works. A university's servers are encrypted by a ransomware operator. Common victims also include corporations, hospitals, or police departments. Only a payment of, say, $1.14 million in bitcoins will release them (see below). The gang may up the ante by threatening to auction off the institution's data if a ransom isn't paid.

Ouch. The University of California San Francisco just paid $1.14 million in bitcoin to ransomware operator Netwalker: https://t.co/fFbBK99lRb

Here's UCSF's statement explaining why it paid the ransom: https://t.co/vBA8dx5GW3 pic.twitter.com/Q0pKQMhscP

— John Paul Koning (@jp_koning) July 1, 2020

Ransomware isn't new. What is new and unique about the recent spate of ransom attacks is that they are:
 
• big-ticket
• factory-scale

That is, the average size of these attacks registers around $170,000, according to Sophos. Prior bouts of ransomware involved much smaller amounts. Secondly, these aren't isolated one-off attacks. They are manufactured at industry-scale with gangs like Ryuk or REvil carrying out dozens of attacks each day.

What makes bitcoin such a great tool for carrying out big-ticket repeatable attacks?

It's not the anonymity. A lot of people think that bitcoin is anonymous – it's actually pseudonymous. All bitcoin transfers can be seen on the blockchain, or Bitcoin's public ledger. This is inconvenient for ransomware gangs because a ransom can be tracked from the original victim to its final destination. While it's possible to use a tool called a mixer to obfuscate one's bitcoin transactions, most ransomware gangs don't bother. Nor do gangs use cryptocurrencies that provide native anonymity, like Monero.

All of this points to the fact that anonymity is not really important to Ryuk, REvil, and other ransomware operators.

So what is it about Bitcoin that is attractive to these gangs? The feature they are after is something called censorship resistance. That is, Bitcoin allows value to be electronically transferred across vast distances without being halted or frozen. A ransomware gang can extort $1.14 from a victim in a country like the U.S. with strong law enforcement and repatriate it to a country with weak law enforcement like Russia, and then sell it for hard cash – all without having to worry about a bank or the FBI freezing their funds somewhere in-between.

Bitcoin isn't the only censorship resistant payment network.

You wouldn't think it, but gift cards like iTunes and Google Play cards are (semi) censorship resistant payments networks, and it is for this reason that they've become popular with criminals. Scammers in call centres located in India frighten their U.S. victims with the fake threat of being apprehended by IRS agents, then tell the victim send a $500 gift card number by text in order to be exonerated. The gang will either resell the card number for cash or spend the balances in an app that they control. Gift card issuers don't have effective measures to freeze balances, so the bad guys can more-or-less use gift card networks with impunity.

So why are today's ransomware gangs using bitcoin instead of gift cards to extort money from the likes of the University of California San Francisco?

At the outset of this post I specified that one of the unique features of modern ransomware is that it is big ticket. A gang that wants to extort a victim for $1.14 million can't do so using gift cards. The maximum gift card size is $500. University of California San Francisco would have to buy 2,500 cards and send the attacker all the card numbers. And then the gang would have to launder all those cards. It's just too inconvenient. 

No, some other payment rail is necessary to do big ticket ransoms. Bitcoin is perfect for this – there is no limit on transfer size.

What about carrying out big ticket ransom attacks via wire transfers? A wire transfer is an electronic payment from one bank account to another, often overseas.

Wire transfers are ideal for big ticket payments, but they aren't censorship resistant. Banks require identification and can freeze suspicious transfers. Our ransomware gang might be able work around this by setting up a network of money mules and accounts using fake ID in a foreign jurisdiction with weak law enforcement. They could then order a victim such as the University of California San Francisco to wire $1.14 million to the gang's foreign bank account. If the $10 million successfully arrives without being frozen, the gang  quickly withdraws the funds as cash before an injunction arrives.

But remember, the second key feature of modern day ransomware is that these gangs are carrying out multiple attacks each day. Setting up fake accounts at various foreign banks in order to receive wire transfers requires a lot of effort. Once one account has been used, it is compromised forever. By contrast, using the Bitcoin network over and over is a cinch. 

In short, wire transfers don't scale. Only Bitcoin allows for the mass production of ransom payments.

So now we know why ransomware gangs like to use Bitcoin. It's not the anonymity. Rather, Bitcoin opens up the field to big-ticket repeatable censorship-resistant payments. 

The next question we may want to ask ourselves is this: should we try and modify the Bitcoin payment network to stop these attacks?

We have a long history of making changes to payments systems that have become popular with criminals. When electronic gold issuer E-Gold became a tool for carders, it had to introduce a customer identification program. Western Union became a haven for “wire money to get me out of jail!” scams. It was fined and introduced much stricter know-your-customer rules. In the early 2010s Green Dot's MoneyPak became a popular network for FBI scams. Green Dot shut MoneyPak down for a year and rebuilt it from scratch to make it much harder for scammers to penetrate.

Bitcoin can't be modified, though. It is censorship-resistant. Which means we need other responses.

One possibility is to ban cryptocurrency. But as I wrote in a recent article for the Sound Money Project, I'm not a big fan of that solution. It seems like overkill. Rather, I suggested putting an embargo on the ransom payments themselves in order to cut off ransomware gangs' revenue. (I also fleshed this idea in an article for Coindesk in 2020.)

Here's another option. The U.S. government could make it difficult for ransomware operators by dusting off Section 311 of the USA Patriot Act. Let me explain how this would work.

A big chunk of the ransom payments that gangs like REvil collect are routed to cryptocurrency exchanges in jurisdictions with minimal anti-money laundering controls. The bitcoins then get converted into cash. Without these liquid offshore exchanges, it would be difficult for ransomware operators to launder their funds into spendable cash.

According to cryptocurrency analysis firm Chainalysis, one large Russian cryptocurrency took in nearly 44% of all ransomware funds sent to exchanges in 2019. (Chainalysis refused to name names). More recently, I stumbled on the following anecdote. It shows how a certain Russian exchange (perhaps the same one that Chainalysis mentions?) converts incoming bitcoin ransomware directly to U.S. dollar banknotes.

Unreal. I've always wondered how ransomware gangs converted bitcoin ransom payments to fiat. For a fee of 4%, this Russian exchange insider does anonymous cash drop-offs. Suggested cash-out amount is $1 million, which weighs 10 kg.

Source: https://t.co/0HSms8tzxN ht @smdiehl pic.twitter.com/lsafCQgV3s

— John Paul Koning (@jp_koning) May 13, 2021

Now, without rogue exchanges such as the one above it would be difficult for ransomware operators to engage in business. But these exchanges are usually located outside of U.S. jurisdiction, so there seems to be little that the U.S. can be done about it.

This is where Section 311 comes in.

Section 311 allows the the Financial Crimes Enforcement Network (FinCEN), an arm of the U.S. Treasury, to designate any foreign based financial institution (like our Russian cryptocurrency exchange) as a primary money laundering concern. Once so designated, it becomes illegal for any U.S. financial institution to interact with the listed entity. 

For those readers with long memories, Section 311 was used to shut down Liberty Reserve, a Costa Rican-based electronic money issuer that became popular with criminals involved in identity fraud and credit card theft. Below is a list of entities that have been designated under Section 311.

Entities designated by FinCEN under Section 311 of the Patriot Act

What really provides Section 311 with the extra oomph for reaching rogue exchanges is that it allows FinCEN to require that U.S. financial institutions stop doing business with any other entity that provides banking services to the designated entity. Think of this strategy as the friend of my enemy is my enemy. Any Russian bank that offers an account to the offending Russian cryptocurrency exchange could be cut off from the U.S. banking system, too. Because the U.S. market is such an important market, most Russian banks will stop doing business with the exchange just to stay friendly with the US.

So Section 311 would cripple ransomware-friendly exchanges by severing them from the financial system. And without these rogue exchanges, it becomes much trickier to be a ransomware gang.

To sum up, Bitcoin is censorship-resistant. That's why ransomware gangs like it. This very same feature also prevents democratic societies from modifying the Bitcoin protocol to exclude ransomware gangs. Bitcoin may be censorship resistant, but the venues where it is traded are not. Section 311 and other tools that allow for leverage over these venues remain one of the best ways to attack bitcoin-based ransomware.

A way to make anonymous online donations

Paying for things online usually means giving up plenty of privacy. But this needn't always be the case. Last night I donated to a local charity via their website and didn't have to give up any of my personal information.

The trick for achieving a degree of online payments anonymity? Not bitcoin, Zcash, or Monero. I used a product created by old fashioned bankers: a non-reloadable prepaid debit card. (I wrote about these cards here and here).

Had I used a credit card or PayPal, all sorts of parties would have gotten access to my personal information including the site owner, the payments processor, my bank, the site owner's bank, the credit card networks, my partner, and many more. To get a good feel for how many different parties touch an online payment, check out this graphic by Rebecka Ricks, which shows how PayPal shares your information.

A powerful visualization by @baricks showing how PayPal shares your data: https://t.co/vd8w8d8xn6 ht @akadiyala

Due to Europe's new privacy laws, PayPal is obliged to make this information public: https://t.co/xmOpfXkNGG pic.twitter.com/vMTQCRfdLA

— John Paul Koning (@jp_koning) August 31, 2019

I bought my prepaid card--a Vanilla card--with $25 cash at a pharmacy. For it to be usable online I had to register it at Vanilla's website. That meant inputting my postal code. But that's all the information that Vanilla asks for. In my case I used my actual postal code, but I doubt that the system would have protested if a privacy-conscious user were to submit the wrong one.*

So at this point I've got a fully-loaded online-enabled card that has not been directly fed any information about my identity. (Note that this is how the process work in Canada. It may be different in the U.S. and elsewhere).

Next step, choose a charity. At the charity's website I entered my Vanilla debit card number, the CVV, and $10 as my amount to donate. The site also asked me to enter the name on the card. Because a prepaid card only says "For You" on it and not your name, just enter that or John Doe. Voila. Payment made:

Why on earth would anyone want to make an anonymous online donation? For my part, I was simply experimenting with my prepaid card. But I can think of several licit reasons for why people might want to donate anonymously with prepaid debit cards:

1. Many people share bank accounts. They might not want their partner to know that they are donating to a cause that their partner might not support.
2. A donor may not want the donee to know their identity lest the donee use it in a way that hurts the donor. For instance, if in public life I am a well-known conservative Evangelical, but I donate to a cause (say abortion education) that I privately support, I might prefer avoiding any chance that the donee leak my information in an attempt to 'out' me.
3. I like the charity, but don't trust it or its chosen payment processors to protect my information from hackers.
4. I don't want the charity to have my information so it can't inundate me with spam.

If non-reloadable prepaid cards can meet people's legitimate privacy needs, there is also a nefarious side to them. Anonymity allows people to evade rules about donations. For instance in Canada, there is a certain type of donation that is highly regulated: political donations. Below I've listed a few keys regulations:

• No cash donations above $20
• No anonymous donations above $20
• The identities of contributors that have given $200 or more must be reported to Elections Canada, which will publish them
• No single individual can contribute more than $1600 in a year.

Canadians have good reasons for supporting these limits. We don't want wealthy people to have an outsized influence on politicians. And we want donations to be transparent so we can see how politicians might be influenced by certain donors.

I can imagine plenty of scenarios in which motivated donors may want to break these rules. Say that a set of business owners in the restaurant industry stand to profit if the Liberal candidate wins because she supports removing regulations that increase restaurant operating costs.

After legally donating $1600 to the Liberals, some less savoury restaurant owners might want to illegally funnel more funds into party coffers. Cheques, credit cards, and other banking routes would be too risky. They establish a clear connection between the owner's identity and the donated funds.

A motivated restaurant owner can instead use $10,000 in cash to buy prepaid debit cards. They then go to the Liberal's website and donate $199.99 fifty times (for a total of $9999.50) using bogus names like John Doe, Jane Doe, etc. Since each transaction is under $200, they won't trigger the rule that requires such donations be reported to Elections Canada. And the Liberal Party probably doesn't have the capacity to cross-check each of the fifty payees to verify that they are associated with real identities.

This rinse-and-repeat strategy highlights one of the ambiguities of prepaid regulations. To reduce the potential for fraud and money laundering, regulators in Canada and the U.S. disallow non-reloadable prepaid cards with a face-value in excess of $500 (I believe that's the number). But since these cards are relatively anonymous, there's nothing preventing a would-be fraudster from using multiple cards to get around the cap.**

In any case, I'm not saying that this sort of donation fraud is occurring. But it's plausible. There's a reason that gift card and prepaid card fraud is rampant in North America. The relative anonymity that cards offer makes them a tempting tool for criminals.

As always, there is a yin/yang nature to anonymous payments. Anonymity is great when it protects well-meaning people from harm, but not so great when it protects bad people from good rules. Striking a balance is tricky.

---

* To access Vanilla's website, I had to disable my tracking blocker. Which means that the website probably has all sorts of processes going on in the background while a Vanilla user enters their postal code. These processes could link the user to their identity by cross-referencing the data gleaned by Vanilla's trackers against other data that has been collected elsewhere. This is probably an issue for these who want all-out privacy, and steps would have to be taken to mitigate information leakage. As they say, there is probably no such thing as pure anonymity, only degrees of anonymity. But for anyone who simply wants to enable a prepaid card in order to prevent their partner or the donee from seeing their transactions, then it's probably not a big deal.

**The way to nip donation fraud in the bud would be to require payment processors to avoid processing any prepaid debit card payment for political parties, or to limit cards to some inconvenient amount like $5 so that a rinse-and-repeat strategy is too costly to perform. It is possible that this tactic has already been adopted by payment processors.

In-game virtual items as a form of criminal money

A few weeks back Vice had an interesting story about Valve, a game maker, putting an end to trade in various in-game items because "worldwide fraud networks" had been using these items to "liquidate" their gains. You can see the blog post from Valve here:

"Why make this change? In the past, most key trades we observed were between legitimate customers. However, worldwide fraud networks have recently shifted to using CS:GO keys to liquidate their gains. At this point, nearly all key purchases that end up being traded or sold on the marketplace are believed to be fraud-sourced."

Having not played a video game since the original Super Mario Bros, this all sounded all very strange to me. But I couldn't resist digging a little deeper. After all, strange media-of-exchange are a major theme here on the Moneyness blog.

Let's set the stage. Anyone who plays Valve games can access something called the Steam Community Market. Players can go to this market to buy and sell in-game items from each other. So for instance, a Counter-Strike: Global Offensive game player may want to buy (or sell) a "skin" which is a texture that can make their gun look fancier. Some skins are apparently quite rare and valuable.

To make a purchase, players will need to have some funds in their Steam Market wallet. Wallets can be funded by credit card or a gift card. The catch is that once funds are on Steam, they cannot be directly transferred to other players. I can't send $100 in Steam balances directly from my Steam wallet to my friend's Steam wallet. Funds can only be used to buy items from other players. Furthermore, there is no way to cash-out of the system. Once money is deposited into Steam, it never leaves.

Now let's get to the fraud stuff, and we'll circle back to Steam later. Say that I'm a fraudster. My shtick is to dial up corner stores, claim that there is a bomb hidden in one of the aisles, and ask for a ransom of $5000 or I will set it off. The store owner has 30 minutes buy five $1000 MoneyPaks, then text me their PIN numbers. Upon which I quickly load the funds into my reloadable Green Dot prepaid debit card, the bomb being a hoax. (I kid you not, this is a true story).

Below is another variation of the scheme, the fraudster claiming to be law enforcement:

Bitcoin extortion scams are all the rage, but other semi-anonymous payments options like Green Dot prepaid MoneyPak cards will do in a pinch: https://t.co/gT2eEItrOw pic.twitter.com/xJCG1W1iDs

— John Paul Koning (@jp_koning) September 11, 2019

There are many versions of these prepaid scams.

In any case, say I pull this threat off fifty times. This leaves me with $250,000 and a pile of prepaid cards. The Green Dot cards aren't linked to my identity, so I needn't worry. But I really want to do something with my money, say buy a house. To do so I will somehow have to get the $250,000 into my bank account, and probably quickly before the money gets frozen. How do I do this safely? Obviously I can't just directly transfer the money from my card to my account. The authorities will connect the dots pretty quick and arrest me. I need to obfuscate the transaction chain.

And that's presumably where Valve's Steam Community Market comes in. If I can send the stolen funds through a market like Steam, maybe I can throw off anyone who comes after me.

First, I go to as many drug stores as I can and use my prepaid cards to buy up Steam gift cards. I'd have to buy around 500 or so $500 cards. And then I upload the $250,000 in card value to a bunch of online Steam accounts that I've created.

Remember, Valve doesn't allow for cash-outs, so the money is effectively frozen in Steam. This is where the items listed on the Steam Market come into play. I now buy $250,000 worth of skins or some other digital knick-knack. These items are now my get-out-of-jail card.

I proceed to sell the items I've stockpiled to other players who desire them for legitimate in-game use. The important thing here is to get actual dollars in return, not Steam dollars. I won't use Steam's in-game market for this, but third-party venues like OPSkins, Bitskins, or Skins.cash. Each of these sites provides an external trading venue where buyers and sellers of in-game items can meet and advertise prices. They also offer a wallet and escrow service to ensure neither buyer nor seller scams the other.

Since I'm in a rush to sell my virtual items, I'll probably lowball my prices on OPSkins, which means I may only get $150,000 for the original $250,000 I've spent. This is a great deal for regular game players. They don't have to fund a Steam account with, say, a $100 credit card transfer. Instead they can buy items from me for $70 on OPSkins and sell them on Steam for $100, saving themselves $30!

I then have OPSkins wire the $150,000 I've earned to my genuine bank account. And now I buy a house. Voila, I've hidden the source of the my money by running it through Steam. Somewhere between converting my prepaid funds into Steam gift cards, and then buying digital items with them, and then selling them, a would-be law enforcement agent will likely lose my scent.

Now that's roughly what I think that Valve is talking about in its blog post when it talks about "fraud networks", add or subtract a few steps. I wouldn't know, I'm just a writer.

What about Valve's response to the fraudsters? From what I gather, one of the most liquid items on the Steam Market are Counter-Strike: Global Offensive (CS:GO) keys. The price of keys is quite stable. Valve sells them at a fixed price, whereas the price of other goods are set by the Steam community, and fluctuate. And so keys have become a sort of currency. By adopting keys as their exit route, fraudsters would have made them even more liquid, and thus better capable of serving as a medium of exchange.  

Valve's defence is to freeze keys. "Starting today, CS:GO container keys purchased in-game can no longer leave the purchasing account," it said. This effectively cuts off any fraudster from existing the system... via the key route. However, there remain many other CS:GO items that folks can buy on Steam and sell on third-party exchanges like OPSkins. And there are other games that provide in-game items, like Dota 2 and Team Fortress 2. One wonders if some other item will become a go-to digital currency for fraudsters now that the CS:GO key route has been terminated. On Reddit, a few players speculate that Dota 2 Arcanas will take the place of CS:GO keys.

Usage of in-game virtual items as a bridge currency of sorts isn't without precedent. When conditions are right, instruments that we don't traditionally use as money, like CS:GO keys, get recruited for that purpose. Usually this occurs because there is some sort of hurdle or friction that prevents mainstream media-of-exchange from functioning, and only an exotic instrument can overcome that speed bump.

Equities are one of the more common exotic media-of-exchange. For instance, to avoid exchange controls Zimbabweans have traded in the inter-listed shares of Old Mutual, lifting them from the Zimbabwe Stock Exchange to London. Argentinians used American Depository Receipts in 2001 to dodge the "corralito". I wrote about both of these here.

More recently, gold was recruited as a payments rail for evading Obama's sanctions.

Heck, even I'm guilty. In Canada, retail foreign exchange conversion fees are ridiculously high thanks in part to our banking oligopoly. So I use Norbert's Gambit to get around the blockade. The gambit involves using dual-listed stocks or ETFs as a bridging asset between U.S. dollars and Canadian dollars. Debit card fraudsters are doing the same when they use CS:GO keys as a go-between asset for cleaning their money.

The desire to engage in trade is voracious. Blockades may be put up, but people will devise all sorts of ingenious monetary solutions for getting around them.

From unknown wallet to unknown wallet

Antony Lewis recently published a useful article on stablecoins. In it he describes something called "permissioned pseudonymity". In traditional payments systems, people only get to access to payments services after opening an account. This requires that they provide suitable identification. So these systems are not pseudonymous. Usage and personal identity are linked.

Stablecoins operators, on the other hand, sever this link. Users can transfer stablecoins to other users without providing personal information. John Doe can pay Jane Doe, no questions asked. Antony calls this permissioned pseudonymity because regulators permit pseudonymous usage of stablecoin networks.

🚨 🚨 30,000,000 #USDC (29,926,581 USD) transferred from unknown wallet to unknown wallet

Tx: https://t.co/ujdi6cvpZ8

— Whale Alert (@whale_alert) October 9, 2019

The above payment is an example of permissioned pseudonymity. It is a $30 million transfer between two unknown wallets along the USD Coin stablecoin network. The operator of this network, Centre, may have no idea who did this transfer.

I do wonder how long regulators will allow pseudonymous usage of stablecoins to continue. Most of the rules surrounding payments emanate from the Financial Action Task Force (FATF), a global committee of regulators that meets together every once in a while to determine how to fight ghoulies like money laundering and terrorist financing. The FATF guidelines are in turn applied by local regulators in each country with some modifications, and monitored by FATF for compliance.

FATF regulations are supposed to be technology-neutral. In short, the same principles apply to new technologies and incumbent technologies alike. This makes sense. We probably don't want regulators to picking winners and losers by setting one set of requirements for companies A-E and another set for F-J. The competition for market dominance only begins after they've complied with the same rulebook.

So far FATF hasn't had much to say on stablecoins. But you can be sure that something is in the works, and it isn't likely to be good for stablecoin operators. The problem is that granting permissioned-pseudonymity to stablecoin operators contradict technology-neutrality. It sets one set of standards for bank accounts and another for stablecoins.

Banks are already obliged to collect the personal information of all their account holders. If two people transfer $30 million along the bank payments network, you can be sure that the banks who manage these accounts have already gone through the costly process of collecting personal information. 

5,000,000 #PAX (4,989,146 USD) transferred from unknown wallet to #Binance

Tx: https://t.co/IRjcUFh1bL

— Whale Alert (@whale_alert) August 14, 2019

Why should stablecoins like USDC and PAX be exempt from this obligation?

Antony suggests that stablecoins qualify for an exemption because they meet regulatory concerns through other sensible means. Because stablecoins use blockchains, and blockchains record transactions, the information trails left by pseudonymous stablecoin users can be traced and monitored for suspicious activity. The stablecoin issuer can then toggle a kill switch and freeze potentially dangerous addresses.

This makes sense. But if stablecoin issuers can avoid identifying its customers by implementing a process of monitoring and freezing, it seems to me that the incumbent technology, the bank account, should also be granted the same opportunity. After all, account-based systems can do kill switches and tracing just as well as stablecoins can.

For instance, say that Citibank were to set up its own pseudonymous account payments network, call it Citibank HushAccounts. Customers can open a HushAccount without providing personal information. They can then use the HushAccount network to trade balances pseudonomously to other account holders. Citibank bankers monitor HushAccount transactional patterns and freeze anything that looks odd. Personal information only needs to be provided when a user wants to cash out of the HushAccounts system.

Of course, we already know that Citibank can't implement HushAccounts. It's illegal. Which underlines my point about technology-neutrality. Why can a stablecoin like USD Coin get away with pseudonymity but Citibank can't?

Let me put it differently. If stablecoin issuers can get away with not collecting user ID, then expect to see Citibank make a few cosmetic changes to its traditional account-based system so that it qualifies as some sort of stablecoin blockchain thingy. And now that it needn't collect as much information about its customers, it can fire a bunch of its compliance staff. Other banks would copy it. Soon we'd get hyper-stablecoinization. Every bank account would be converted into a stablecoin. But FATF rules aren't supposed to favour any one technology.

So for the sake of maintaining neutrality, I wouldn't be surprised to see regulators put an end to pseudonymous stablecoin usage. Stablecoin issuers will only be able to give out addresses to people who have passed through some sort of know-your-customer process.

🚨 🚨 20,000,000 #USDT (20,113,052 USD) transferred from unknown wallet to unknown wallet

Tx: https://t.co/f7BTC2S6U4

— Whale Alert (@whale_alert) September 27, 2019

There's a second possibility. As Antony points out, there is one notable regulatory exception to universal identification in payments. In many parts of the world, people can buy prepaid debit cards (or in Europe, e-money) without providing any ID. This provides the card owner with pseudonymous access to the Visa or MasterCard networks. I've written about these cards before (in fact, it's one of the most popular posts I've ever written). You can also trek over to my article at Sound Money Project on the topic.

Stablecoins, like prepaid debit cards, might be granted their own exemption.

There is a caveat to pseudonymous prepaid access. Regulators have set a very low ceiling for the amount of pseudonymous value that prepaid cards or e-money wallets can hold. In the case of the U.S. it's just $1,000. (In Europe, it's just 150 euros). Anything above that and a prepaid card holder must submit identification. There are other limits too. In the U.S. the cards must be non-reloadable, and people can't use them for person-to-person payments, at ATMs, or for international purchases. This makes for an extremely constricted payments product.

Regulators believe that by keeping the pseudonymous prepaid ceiling low and reducing the features that a card offers, they achieve two things. The risk of money laundering and terrorist financing are minimized. At the same time the unbanked and those without ID still get access to the retail payments system.

If FATF were to allow stablecoins to offer a limited amount of pseudonymity, the ceiling for it would probably be quite low, much like prepaid debit cards. No more $30 million person-to-person payments, just $20-$2000 ones. After all, it's hard to make an argument for why genuinely needy folks without IDs would need to make million dollar stablecoin transactions. 

I should point out here that I'm not saying that I'm a fan of FATF and its mission to unveil every single transaction. I've written many times about the benefits of financial anonymity. And a lot of smart people that I read think that the cost of enforcing anti-money laundering rules far outweighs any benefits that it provides. All I am saying is that I suspect that permissioned pseudonymity for stablecoins isn't going to last very long, in its current form. It'll either be banned altogether, or a very low ceiling will be set on it.

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P.S. If I had to predict, I'd go with a ban. It's easy to get around a ceiling. If the ceiling is set at $1000, then users can set up 1000 pseudonymous accounts in order to get $1 million in pseudonymity.

Starbucks, monetary superpower

I recently spent some time on Twitter discussing the monetary wonders of Starbucks. In this post I'll bring a bunch of tweets together into a single blog post.

I don't go to Starbucks very often, so I only recently learnt that the company has succeeded in getting many of its customers to stop using cash and debit/credit cards to buy coffee. Instead, they are using  Starbucks's own payments option:

Wow Starbucks, what a great gig.

Starbucks has ~$1.6 billion in 'stored value card liabilities' i.e. the Starbucks Card. So ~6% of the firm's liabilities are comprised of coffee addicts paying 0% for the privilege of lending to their supplier.
Source: https://t.co/nGH2arujYz pic.twitter.com/cGcSW3L4MM

— JP Koning (@jp_koning) August 11, 2019

Starbucks has around $1.6 billion in stored value card liabilities outstanding. This represents the sum of all physical gift cards held in customer's wallets as well as the digital value of electronic balances held in the Starbucks Mobile App.* It amounts to ~6% of all of the company's liabilities.

This is a pretty incredible number. Stored value card liabilities are the money that you, oh loyal Starbucks customer, use to buy coffee. What you might not realize is that these balances  simultaneously function as a loan to Starbucks. Starbucks doesn't pay any interest on balances held in the Starbucks app or gift cards. You, the loyal customer, are providing the company with free debt.

Starbucks isn't the only firm to get free lending from its customers. So does PayPal. That's right, customers who hold PayPal balances are effectively acting as PayPal's creditors. Customer loans to PayPal currently amount to over $20 billion. Like Starbucks, PayPal doesn't pay its customers a shred of interest. But Starbucks's gig is way better than PayPal's. PayPal is required to store customer's funds in a segregated account at a bank, or invest them in government bonds (see tweet below). So unfortunately for PayPal, it earns a paltry amount of interest on the funds that customers have lent it.

PayPal is a good example of a modern 'narrow bank'. Customers have deposited ~US$20 billion at PayPal. And PayPal invests these funds in very boring things listed below, like bank deposits, time deposits, government debt etc.

Source: https://t.co/snJel203QM pic.twitter.com/EDfMA2Wkux

— JP Koning (@jp_koning) August 21, 2019

Starbucks, on the other hand, doesn't have to keep customer funds in a low yielding segregated account or government bonds. Why is that? PayPal allows people to cash-out of PayPal dollars into regular dollars, so for regulatory purposes it must keep an adequate reserve on hand to facilitate redemptions. But the only way to cash out of Starbucks balances is to buy a coffee--a promise that Starbucks can always keep! And so Starbucks can immediately put its customer loans to work in higher-yielding opportunities like funding its operations and expansion.

In addition to borrowing from its customers, Starbucks also borrows from professional investors. Here's a list Starbucks's long-term debt:

Starbucks is paying an interest to bond and note-holders that ranges as low as 0.46% (on its yen notes maturing in 2024) to 4.5% (on its 2048 notes). You can see why borrowing from customers in the form of stored value card liabilities is the better option. By expanding its borrowing from its non-professional lenders and using the proceeds to cancel its debts to professional lenders, Starbucks can make an immediate profit.

But there's more. As I pointed out in the following tweet, don't forget breakage. Bond and note holders are pros. They don't forget about debts. But customers aren't so exact. They are sloppy, or busy, or forgetful, which means that many gift cards and balances will go unspent:

Few companies can get that much free financing. But don't forget breakage—balances that will never be redeemed. In 2018 Starbucks recorded breakage of $155 million,~10% of all card balances.

So the true rate at which customers are lending to Starbucks is probably closer to -10%. pic.twitter.com/hRaN7LGoEf

— JP Koning (@jp_koning) August 11, 2019

Each year Starbucks recognizes that a portion of its stored value liabilities will be permanently lost. This is known as breakage. Starbucks recognizes this amount as profit. In 2018 the company recognized $155 million in breakage, around 10% of all stored value balances. Wow! Starbucks already pays just 0% on its debts to customers, but add in breakage and that equates to a roughly -10% interest rate!

On Twitter, Wayne points out to me that I need to add back the impact of Starbucks rewards. App users receive stars on each purchase which can be saved up for free coffee. This functions as a form of implicit interest that Starbucks pays to its customers.

I earn about 50% equivalent interest per year on my Starbucks card. 2 Americanos per week earns me a free one about once every 3 months. Roughly $12 per year in free purchases. I keep between $10-$25 balance on the card. Earning $12/year on a $25 investment is a good return.

— Wayne Culbreth (@wayne_culbreth) August 11, 2019

That's a good point. But if were going to bring rewards into our calculation, then there are other non-pecuniary flows that need to be added in too. Keep in mind that each payment made through the Starbucks app is a payment that isn't made by credit card. Since each credit card payment will cost Starbucks 1-2% in interchange fees paid to the card networks and banks, the company saves a lot of money by guiding customers to its payments app. As for Wayne, while he may earn an implicit interest return in the form of Starbucks points, by forgoing a card payment he's giving up on the associated cash-back or airline points.

Another flow that needs to be accounted for is data. By capturing the customer's wallet, Starbucks is getting loads of free but valuable personal information that would otherwise be lost, or for which it would have to pay. Any customer who pays with cash forgoes rewards, but at least they get to retain their information. 

Adding all of this up, (0% interest + breakage - rewards + interchange savings + customer information), Starbucks's stored value liabilities are a terrific liability to have.

More generally, I think this calculation demonstrates how providing financial services to a retail customer base is a great business. Retail customers don't seem to be too fussy about the return they get. And they are busy and distracted and sloppy and forgetful. Take central banking, for instance, which serves a retail clientele. People are pretty happy to hold banknotes that pay 0%. But you never see businesses or professional investors hoarding banknotes. They quickly return the cash they take in during the course of the day to their bank so that they can harvest interest. Commercial banking is also a good example. Like Starbucks, banks are able to borrow from their retail customers at a measly rate approaching 0%. But professionals who lend to banks by purchasing their bonds require a much higher rate. To top it off, retail customers unnecessarily sign up for high-fee products and avoid changing banks when there is a cheaper option.  

Why doesn't every retail chain try get into this game? By borrowing as much as they can from the non-professional public, they'd steal plenty of profitable business from central banks and retail banks. Well they do. Gift cards are a big business. And if you think about it, retailers are perfect candidates for providing monetary services to the masses. Like banks, they already have a network of physical stores. But none of them have been successful at it as Starbucks. Walmart is much bigger than Starbucks, for instance, but it has just as many gift card balances outstanding:

Starbucks is really good at harvesting seigniorage.

Walmart's annual sales are 20x larger than Starbucks sales (~$500b vs $25b). But Walmart only has $1.9 billion in unredeemed gift card balances, not much more than Starbucks. Source: https://t.co/LBs6DE1cGq pic.twitter.com/wtJltMt26L

— JP Koning (@jp_koning) August 11, 2019

Perhaps Starbucks's success has to do with the regularity and homogeneity of Starbucks purchases? And so customers are willing to preload a dedicated account? I'm not sure.

In any case, there are probably a few Starbucks executives who'd love to grow the amount of negative yielding liabilities that the firm issues. Why stop at $1.6 billion in stored value liabilities? Why not grow the program to $5 billion, $10 billion, or $100 billion? It would be a terrific business line to get into.

The problem here is that Starbucks only sells coffee. Coffee is great, but the demand for dollars that are only useful for buying coffee will always be limited. To really grow the amount of stored value liabilities it issues, Starbucks would have to increase the usefulness of Starbucks dollars. One way to do this would be to open up the Starbucks app up to other stores. If consumers could also buy Big Macs with the balances on Starbucks App, this would increase the demand for Starbucks balances. To secure McDonald's cooperation, Starbucks would have to share the savings, breakage, and data. Maybe companies like Home Depot and Costco would join the Starbucks-McDonald's alliance. (And other chains, say Kroger and Burger King, might join the competing Walmart Pay alliance).

Sure, each of these companies could simply pursue their own independent stored-value liability programs. But wouldn't an alliance be better? From the customer's perspective, balances held in a single payments app that can be spent at Starbucks, McDonald's, Home Hardware, or Costco would be far more useful then dollars held in four separate and walled-off apps. And so collectively these stores should be able to get the public to hold more stored value card liabilities than they could individually. Which means more breakage, free loans, and data for everyone (and less for the banks, card networks, and central banks).

Who knows if it would be successful. And it might not even be possible from a regulatory perspective. But it would be tempting, no? In a world where most debtors have to pay interest, being  a debtor who earns interest is pretty hard to beat.

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*I believe that current portion of deferred revenue is equal to around $174 million. This comes courtesy of the current portion of an up front royalty payment from Nestlé. So the stored value card liability is actually closer to $1.46 billion. Still pretty high.