FinCEN's Director on Virtual Currencies

By Bradley Jansen
FreeBanking.org
Saturday, April 20, 2013

http://www.freebanking.org/2013/04/20/fincens-director-on-virtual-currencies/

Earlier this week, FinCEN Director Jennifer Shasky Calvery addressed the National Cyber-Forensics Training Alliance CyFin 2013 Conference.

She explains again how the Financial Crimes Enforcement Network (FinCEN) gets its data from the reports it mandates that banks use to spy on their customers against them. Lots and lots of reports.

But she promises:

"However, right now this is long and arduous work as analysts sift through hundreds and sometimes thousands of reports. Very soon, new capacities made possible by our internal technology modernization will allow our analysts to deal with such data sets to find leads in a fraction of the time previously necessary. Very soon, we will be able to point law enforcement and other stakeholders precisely to where they should be looking. Our analysts, working hand- in-hand with our superb technology team, are now putting these new capacities into place."

But her talk really focused on "Emerging Payment Systems." Her comments have echoed mine (from an entirely different perspective) that technology (and specifically mobile apps) offer great opportunities (for free banking) and that those not well served by our current system (the "unbanked" in the US--immigrants, poor, racial and ethnic minorities--and people in countries with less mature financial systems or sound currencies) are a great target market.

"As we all know, during the past decade, the development of new market space and new types of payment systems have emerged as alternatives to traditional mechanisms for conducting financial transactions, allowing developing countries to reach beyond underdeveloped infrastructure and reach those populations who previously had no access to banking services. For consumers and businesses alike, the development and proliferation of these systems are a significant continuing source of positive impact on global commerce."

Don't worry, FinCEN is working to strangle these initiatives in their crib with their regulations. She pays special attention to "crypto-currencies" in her talk.

"We’re viewing our analytic work in this space as an important part of an ongoing conversation between industry and law enforcement. While probably most of today’s audience understands what these emerging payments systems are and how they work, many line analysts, investigators, and prosecutors in law enforcement may not, and part of FinCEN’s role is to help be the bridge to explain these new systems. FinCEN is dedicated to learning more about digital currency systems, along with other emerging mechanisms, to protect those systems from abuse and to aid law enforcement in ensuring that they are getting the leads and information they need to prosecute the criminal actors. As our knowledge base develops, in concert with you, we will look to leverage our new capabilities to identify trends and patterns among the interconnection points of the traditional financial sector and these new payment systems.

In addition to developing products to help law enforcement follow the financial trails of emerging payments methods, FinCEN also develops guidance for the financial industry to clarify their regulatory responsibilities as they relate to emerging areas."

And, as our Bitcoin fans know--at least those who follow my posts here or my rants on our Facebook page, FinCEN has "virtual currencies" in their sights. And, remember too, it was FinCEN that shut down e-gold back in the day and crippled the crypto-currency movement last century.

I'll quote her in the entirety of her virtual currency remarks:

"In fact, just last month, FinCEN issued interpretive guidance to clarify the applicability of BSA regulations to virtual currencies, such as Bitcoin, which has in recent weeks gained significant attention. The guidance responds to questions raised by financial institutions, law enforcement, and regulators concerning the regulatory treatment of persons who use virtual currencies or make a business of exchanging, accepting, and transmitting them.

FinCEN’s rules define certain businesses or individuals as money services businesses (MSBs) depending on the nature of their financial activities. MSBs have registration requirements and a range of anti-money laundering, recordkeeping, and reporting responsibilities under FinCEN’s regulations. The guidance considers the use of virtual currencies from the perspective of several categories within FinCEN’s definition of MSBs.

The guidance explains how FinCEN’s “money transmitter” definition applies to certain exchangers and system administrators of virtual currencies depending on the facts and circumstances of that activity. Those who use virtual currencies exclusively for common personal transactions like receiving payments for services or buying goods online are not affected by this guidance.

Those who are intermediaries in the transfer of virtual currencies from one person to another person, or to another location, are money transmitters that must register with FinCEN as MSBs unless an exception applies. Some virtual currency exchangers have already registered with FinCEN as MSBs, though they have not necessarily identified themselves as money transmitters. The guidance clarifies definitions and expectations to ensure that businesses engaged in similar activities are aware of their regulatory responsibilities and that all who need to, register appropriately."

The second half of her speech talked about account takeovers via malware, risks with third party payment processors, improvements they are making to their analytical work (after some false starts!), their public-private partnerships with industry, and her personal initiative "The Delta Team" ("The purpose of the Delta Team is for industry, regulators, and law enforcement to come together and examine the space between compliance risks and illicit financing risks. The goal is to reduce the variance between the two.").

And let's not forget FinCEN's dreams of global domination. They are in a partnership of 130 other "Financial Intelligence Units" as part of the Egmont Group.

The text of her remarks is available at the following link:
http://www.fincen.gov/news_room/speech/pdf/20130416.pdf

Reprinted with permission.

Flerovium: Tangible Nanomoney

By Jon Matonis
Forbes
Sunday, April 14, 2013

http://www.forbes.com/sites/jonmatonis/2013/04/14/flerovium-tangible-nanomoney/

I need a break from Bitcoin. Let’s discuss the real future of money.

Beyond stable isotopes and naturally-occurring materials are the superheavy elements or SHEs. Scientists have recently added two new man-made elements to the periodic table — flerovium (element 114) and livermorium (element 116), with chemical symbols Fl and Lv.

After being created by smashing atoms together, these materials decay within seconds but long-lived SHEs are a theoretical possibility. This undiscovered region in the periodic table where heavy elements become stable again is known as the “island of stability,” first proposed by Glenn Seaborg in the late 1960s. If individuals prefer something more tangible over an amorphous cryptocurrency like bitcoin, then the edges of molecular matter in a nanotechnology future may hold the answer.

If some form of physical specie is even useful in an era of ubiquitous artificial molecular machine systems, money would still require certain attributes such as being a store of value, divisible, portable, safe, unable to counterfeit, and self-validating.

Nanotechnology scientist Robert Freitas suggests that the future of money lies with elements like flerovium, or what he refers to as tangible nanomoney. Flerovium is a radioactive chemical element first created in 1999 at the Flerov Laboratory of Nuclear Reactions in Dubna, Russia by colliding Plutonium-244 and Calcium-48 nuclei. Prior to May 30th, 2012, the unstable isotope was known as ununquadium.

After restricting his analysis to ordinary matter, as opposed to antimatter, Freitas compares the rarest elements along the natural isotope spectrum of potential monetary candidates such as technetium, helium, xenon, osmium, tantalum, and gold (however in a nano-age, easily extractable inert rare elements will have alternatives).  Ultimately concluding that a man-made superheavy element like flerovium best fits the overall criteria for physical specie, he describes how the element could likely be introduced into society circulating as coinage.

A flerovium coin would be fused with cheaper bioinert materials of the nano-age such as gold, platinum or diamond. Such a coin would be sufficiently costly to manufacture and have a relatively long half life, possessing negligible radiation and biotoxicity risk due to the very low concentration of SHE trace amounts.

These hypothetical SHE coins would be stable and long-lived. Freitas estimates that a coin with $1 million face value would only need to contain 10^⁹ SHE atoms worth $0.001/atom. Therefore, assuming a 10⁶-year half life, there would be only ~2 disintegration events per day putting it well below the disintegration levels of today’s base metal coinage. Rather than suffering from the insidious effects of government-induced inflation and coin clipping, market-based nanomoney would lose value due to radioactive decay. A million-dollar coin would lose approximately ~$0.50 per year or ~$500 per millennium from disintegration.

In addition to flerovium, Freitas admits that some other relatively stable superheavy elements may also be “coined” for the ultimate tangible nanomoney. So that’s the choice for our nonpolitical money of the singularity — low radiation coinage or digital bitcoin, you decide.

Bitcoin and the Rebirth of Financial Safe Havens

By Jon Matonis
American Banker
Thursday, April 11, 2013

http://www.americanbanker.com/bankthink/bitcoin-and-the-rebirth-of-financial-safe-havens-1058216-1.html

Like never before, financial privacy and safe havens are under attack the world over.

Banks and even entire jurisdictions are feverishly responding to increased government scrutiny from the world's monetary power centers in the name of exposing political corruption, combating terrorism, and preventing tax evasion.

Full financial transparency is the new mantra and it's being invoked in the name of social justice. The International Consortium of Investigative Journalists recently released "Secrecy for Sale: Inside the Global Offshore Money Maze," a report that focuses on "exposing hidden dealings of politicians, con men and the mega-rich."

But why are private individuals lumped together with politicians who choose to be public figures representing the interests of their constituencies? Should private individuals and political figures be treated in the same manner regarding financial privacy?

Attorney Jenice Malecki of Malecki Law told me: "No, they should not. When you become a political figure, you agree to give up some of your privacy rights. You also need to be more transparent, so people know who you really are, whether they should believe what you say."

Politicians who do not voluntarily submit to monitoring of their financial activities will not be trusted.

"Private individuals should have more privacy, as they have not placed themselves into the political arena. They have not agreed to give up their privacy," adds Malecki. However, she also concedes that when it comes to offshore numbered accounts, "it does seem that banking secrecy is eroding. Slowly, but surely, banks are releasing information for governmental investigations."

Violations of everything from know-your-customer rules to the Foreign Account Tax Compliance Act  can all be loosely categorized as the politically incorrect crime of money laundering. But as the investor and author Doug Casey says, "it's a completely artificial crime. It wasn’t even heard of 20 years ago, because the 'crime' didn’t exist." Moving money around was simply called banking. Furthermore, Casey says, "The war on drugs may be where 'money laundering' originated as a crime, but today it has a lot more to do with something infinitely more important to the state: the War on Tax Evasion."

Almost simultaneously with the recent jihad against tax dodgers, decentralized cryptocurrencies such as bitcoin arrived on the scene in early 2009 and now provide an outlet for personal wealth that is beyond restriction and confiscation. The exchange rate for government fiat currencies may be volatile now, but as the market price eventually finds equilibrium and stabilizes, bitcoin will become an important store of value.

Think of bitcoin as your own personal financial safe haven or offshore bank. Previously, you had to board a jet or hire an attorney to set up legal entities and open bank accounts in private banking jurisdictions like Liechtenstein, Luxembourg, the Cayman Islands or the Cook Islands.

Simply by leveraging the distributed bitcoin block chain, which records all transactions in the system and prevents double-spending without identifying the parties by name or location, individuals can protect their wealth from privacy violations and indiscriminate confiscation without leaving the keyboard. This represents a powerful new development that the world has not seen before and it will have a profound impact on the global asset management industry specifically.

Today's best tax havens combine a no-tax jurisdiction with extreme banking secrecy enshrined in law where bank employees could face imprisonment for disclosing bank customer details to third parties or parties outside of the bank. Unsanctioned disclosure of bank account information in most tax havens is considered a criminal offense punishable by incarceration and monetary fines.

Sanctioned disclosure usually requires a recognized court order and typically hinges on the distinction between legal tax avoidance and tax evasion. Offshore jurisdictions have been feeling the pressure for several years to remove that distinction and open the banking records regardless.

The global trend persists toward cleaning up the high-risk and uncooperative countries on the intergovernmental Financial Action Task Force’s blacklist. Ultimately, no jurisdiction will be exempt. On the complementary Organisation for Economic Co-operation and Development gray list, the tiny alpine principality of Liechtenstein has been amending tax laws in a move to anti-secrecy compliance. Similarly, as the small haven of Cyprus had built up a burgeoning financial center for the free flow of capital within the eurozone, it too had to be restrained, even if that meant egregious depositor "haircuts" of up to 60%.

Future regulatory and confiscatory attacks on safe havens and banking secrecy will become irrelevant, because bitcoin provides for a personal "offshore center" under direct and sole control of the individual. However, Malecki cautions, "If [the] bitcoin currency's respect and security grows, the governments will also find a way to keep on top of bitcoin monitoring and enforcement.

"I think that determining 'legitimacy' is difficult," she says, "but as with political asylum, perhaps the financial world needs some financial asylum – which has very specific criteria, review and oversight. Without that, there is bound to be abuse" by governments.

Legitimacy is a politically charged term. One person's legitimacy may be another person's aggressive and unjustifiable overreach. Also, what a certain government sees as legitimate may be viewed in other parts of the world as a violation of fundamental human rights. This is clearest in authoritarian regimes that impoverish and imprison their political opponents for so-called crimes against the state.

It all depends of who is performing the oversight. I am not quite sure how any political oversight could function effectively while still protecting the financial privacy rights of individuals. Thankfully, it doesn't matter anymore.

Government Fees, Parking Tickets May Soon Be Paid in Bitcoin

By Jon Matonis
PaymentsSource
Monday, April 8, 2013

http://www.paymentssource.com/news/government-fees-parking-tickets-may-soon-be-paid-in-bitcoin-3013753-1.html

While some call Bitcoin an “existential threat to the state,” local governments could soon embrace the digital currency and payment system as a practical alternative to credit and debit cards.

E-Gov Link, an Ohio company that helps municipalities accept payments online for parking tickets, permits, and the like, now allows its customers to take bitcoin. Noting that "credit card purchases tend to carry high transaction costs due to the middleman and due to the high costs of fraudulent online purchases," E-Gov President Bill Nadler emphasized in a press release, "having a payment option that doesn’t carry that heavy transactional cost is definitely a plus." Bitcoin transactions can be processed at a fraction of the cost of other payment methods because they avoid the interchange structure of the legacy card processors.

Aside from the benefits to merchants, bitcoin payment choices have significant benefits to consumers who may have already received bitcoin from others in the sale of products or services and do not necessarily want to convert out of the digital currency. Broadening merchant acceptance expands the "network effect" of a young currency and starts to make Bitcoin viable as an end-to-end payments system.

"We know the bitcoin community is passionate about using bitcoin for payments, and will be demanding it of their local governments," said Nadler. "We’re happy to be here to answer the call, as municipalities scramble to find partners to help them with bitcoin."

Naturally, the use of bitcoin in local government settings will not be leveraging its optional anonymity properties, thus demonstrating bitcoin's overall flexibility when compared to physical cash.

"We look at bitcoin as a competitive advantage," says Jerry Felix, Vice President of Software Development at E-Gov Link. The company sees it as a natural evolution for governments to accept bitcoin as the currency gains popularity and like in other merchant categories, supporting bitcoin first creates a first-mover advantage. E-Gov Link focuses on integrating bitcoin payments into the shopping cart experience while relying on payment processor BitPay to manage the bitcoin wallets and currency conversion.

"We have customers across the U.S., in over 30 states. We're dealing with small and medium sized municipalities – cities, towns, townships, villages, and counties, and we provide web solutions for them," adds Felix. Marquee client examples for the web solutions provider include municipalities like Niagara Falls, N.Y., and Skokie, Ill.

For now, a municipality has to step forward and ask E-Gov Link to enable bitcoin payments – which is peculiar because other payment methods are not selectively disabled.

It would be far more interesting for these local governments to make it known to citizens that the bitcoin payment choice is an option. Still, the offering from E-Gov Link is a major step in that direction because bitcoin first has to be a viable option for the local government. Whether bitcoin demand is merchant-driven or consumer-driven, one thing is clear. Greater merchant choices and new payment categories contribute to the increasing value of the Bitcoin network.

Payments to government entities stand as one of the primary economic lynchpins for the preferred monetary unit. The obligation of the political authority to accept tax payments in government fiat currency is what underlies its value. While this E-Gov Link move does not cover tax payments demanded in a particular monetary unit, it can be seen as a precursor to a political authority expressing a preference for payments in a digital currency.

Bitcoin Obliterates "The State Theory Of Money"

By Jon Matonis
Forbes
Wednesday, April 3, 2013

http://www.forbes.com/sites/jonmatonis/2013/04/03/bitcoin-obliterates-the-state-theory-of-money/

Once you get past the childish title, the recent bitcoin piece from Karl Denninger raises some issues that warrant consideration from bitcoin economists. Denninger is an intelligent student of the capital markets and his essay deserves a serious reply.

The economic contribution of his essay is that it represents the thesis advanced by German economist Georg Friedrich Knapp in The State Theory of Money (1924), an expose advocating the Chartalist approach to monetary theory claiming that money must have no intrinsic value and strictly be used as tokens issued by the government, or fiat money. Today, modern-day chartalists are from the school of thought known as Modern Monetary Theory (MMT).

Without getting into the intrinsic value debate, this is where I strongly depart from Denninger, because if we accept the thesis that all money is a universal mass illusion, then a market-based illusion can be just as valid or more valid than a State-controlled illusion. What Denninger and Greenbackers and MMT supporters reject is the notion that monetary illusions themselves are a competitive marketplace, falsely believing that only the State is in a ‘special’ position to confer legitimacy in monetary matters.

Regarding this issue of State-sanctioned legitimacy, bitcoin as a cryptographic unit seeks and gains legitimacy through the free and open marketplace. It is not a governmental instrument of legal tender that requires regulatory legitimacy and coercion by law in order to gain acceptance.

Therefore, the path to widespread adoption of bitcoin hinges on three primary market-based developments: (a) robust and liquid global exchanges similar to national currencies that can offer risk management via futures and options, (b) more user-friendly applications that mask the complexities of cryptography from users and merchants, and (c) a paradigm shift towards “closing the loop” such as receiving source payments and wages in bitcoin to eliminate the need for conversion from or to national fiat.

Even after graciously accepting Denninger’s definition of what the ideal currency would be (which I don’t) and searching for any economic nuggets of value, his arguments can be distilled into four main criticisms of bitcoin as a monetary instrument. First, bitcoin does not provide cash-like anonymity. Second, bitcoin transactions take too long for confirmations to be useful in everyday transactions. Third, bitcoin exhibits irreversible entropy.  Fourth, the decoupling of the stateless bitcoin from the obligation of monetary sovereigns is considered a fatal weakness.

Now that we identified the objections, let’s take these in order.

On the first point surrounding bitcoin anonymity, Denninger only embarrasses himself with this criticism. By default, bitcoin may not offer anonymity and untraceability like our paper cash today, but it is better described as user-defined anonymity because the decision to reveal identity and usage patterns resides solely with the bitcoin user. This is far superior to a situation where users of a currency are relegated to seeking permission for their financial privacy which is typically denied by the monetary and financial overlords. Also, his capital gains tax issue is a non-starter because it’s a byproduct of a monopoly over money.

His second criticism of a lack of utility in the ‘goods and service preference’ due to timing of sufficient block chain confirmations has some merit. However, advances have been made in the use of green addressing techniques that solve the confirmation delay problem by utilizing special-purpose bitcoin addresses from parties trusted not to double spend.

Denniger’s third criticism that bitcoin exhibits irreversible entropy is confusing. Typically, entropy refers to a measure of the unavailable energy in a closed thermodynamic system that is also usually considered to be a measure of the system’s disorder. In the case of bitcoin, I suspect Denninger is taking it to mean the degradation of the matter in the universe because of his explicit comparison to gold. While it is true that bitcoins lost or forgotten are ultimately irretrievable, I view that as a feature not a bug because it is the prevailing trait of a digital bearer instrument. Two bitcoin digital attributes that make it superior to physical gold are its ability to create backups and its difficulty of confiscation. Furthermore, the number of spaces to the right of the decimal point (currently eight) is immaterial to bitcoin’s suitability as a monetary unit.

Now for the big and final one. Denninger asserts that monetary sovereign issuers possess not only the privilege, but the obligation, of seigniorage, which Denninger refers to as bi-directional since sovereigns have the responsibility of maintaining a stable price level during times of both economic expansion and economic contraction. As a product of Hayekian free choice in currency, market-based bitcoin is decentralized by nature and poses a false comparison to the century-old practice of central bank monetary manipulation. Fear not deflation.

Governments have appropriated the monetary unit for their own benefit by declaring it the only preferred monetary unit for payment of taxes to the State. Believing that governments have sincere and good intentions in administering the monetary system is akin to believing in fairy tales. Control of the monetary system serves one and only one interest — the unlimited expansion of the sovereign’s spending activity to the detriment of the unfortunate users of that monetary unit. Decentralized Bitcoin obliterates this sad state of affairs.

Denninger’s biased and establishment preference for a monetary sovereign serves only to harm his analysis because it undeniably closes him off from alternative, and usually superior, free-market monetary arrangements. More damaging, however, is the fact that it places him outside of the mainstream in free banking circles and squanders his remaining quasi-libertarian credibility as a champion of markets.

FATCA Is Far from a Done Deal

By Jon Matonis
American Banker
Monday, April 1, 2013

http://www.americanbanker.com/bankthink/fatca-is-far-from-a-done-deal-1057947-1.html

Largely affecting those banks outside of the U.S., the Foreign Account Tax Compliance Act requires all foreign financial institutions to report the activities of their American clients to the Internal Revenue Service. But given the recent demands from other nations hinting at reciprocity, the overreaching legislation could impact banks and financial institutions in the U.S. as well.

Now, there is the additional element of certain key countries rejecting FATCA outright, and the Asia-Pacific region could end up holding the most sway.

Cited as a hindrance to foreign investment that would ultimately dampen U.S. economic growth and threaten American jobs, the FATCA penalties for noncompliance provide a strong incentive for overseas investors to avoid U.S. depository institutions altogether. Tax Management International Journal cites 11 reasons why FATCA must be repealed. Reason number one is "the height of arrogance."

It is either the reciprocity angle or the cascade effect of China's reluctance that has the greatest potential to derail FATCA.

"The United States should be moving toward full reciprocity," Georgetown Law School Professor Itai Grinberg, a former Treasury official, told Reuters. He added that it would be "deeply hypocritical" for the U.S. to ask for information on American taxpayers "without offering some kind of reciprocity."

Because direct reciprocity may mean foreign banks violating the privacy laws of their own jurisdictions, the Treasury Department has started negotiating bilateral agreements so that foreign governments can aggregate the bank data necessary for the IRS.

Attorney Brian Mahany of Mahany & Ertl, a law firm specializing in offshore reporting and compliance, believes that reciprocity is a bit misleading. "We are one of the few countries that tax based on worldwide income. Reciprocity isn't as important to most other nations," he added.

Also, the U.S. is one of the worst offenders globally when it comes to tax havens and "secrecy jurisdictions." For instance, Mahany said "many people, including Chinese nationals, hide money here." While President Obama has asked Congress for reciprocity, he is dealing from a position of weakness. "The support for FATCA is not very strong," Mahany added.

However, with global financial transparency on the increase and more countries considering taxation on citizen's worldwide income as a way to combat growing budget deficits, reciprocity with U.S. financial institutions starts to look appealing.

On the China issue, Mahany concedes that the U.S. government will never get every nation to join FATCA and the Asia-Pacific countries are heavily influenced by Beijing. He states, "China is certainly an important player. Currently, none of the Asian-Pacific countries are signed up, although Japan will probably be the first. Without Singapore, China, Hong Kong and Macau, FATCA faces real challenges."

James Jatras of the Repeal FATCA campaign claims that Hong Kong, like the People’s Republic of China, is not even on the list of 50 countries the Treasury claims to be negotiating with.

There will probably be so few U.S. citizens holding bank accounts in China that the cost of implementing FATCA outweighs the benefit to China's financial institutions. Also, the Chinese taxpayers with U.S. bank accounts appear to be of minimal interest to the Chinese government, according to Lisa Smith of iExpats.com.

"Before rushing to safe keep all your money in Communist China, remember that even if China elects to ignore FATCA, they may still cooperate with the IRS on a case-by-case basis," according to Mahany. China and the U.S. signed a Mutual Legal Assistance Agreement in June of 2000.

However, none of this potentially disruptive turmoil means that financial institutions should put FATCA-related IT infrastructure plans on hold until China makes its decision, because foreign banks and other financial institutions are currently ill-prepared for FATCA.

According to Mahany, "Implementation has been delayed once but folks should not depend on that happening again. The penalties for not complying outweigh the risks of noncompliance."

Meredith Moss of Finomial believes "that a technology solution is the only way to go, given the tremendous amount of data, PDFs and paper documents to sift through." She says that banks moving forms online and creating a comprehensive FATCA audit trail will demonstrate diligence to the regulators and that "due diligence should be underway by January 2014 and completed by July 2014."

Although experts in the FATCA preparation business tend to agree that moving forward with expensive FATCA compliance plans is the prudent and logical step to be taking now, a comprehensive and worldwide FATCA rollout is far from a foregone conclusion. For those financial institutions and their shareholders offended by the overreaching legislation and lack of respect for mutual sovereignty, the cost savings alone may start to make FATCA's non-compliance penalties look tolerable.

Tradehill Exchange Adds Dark Pools Of Bitcoin Liquidity

By Jon Matonis
Forbes
Thursday, March 28, 2012

http://www.forbes.com/sites/jonmatonis/2013/03/28/tradehill-exchange-adds-dark-pools-of-bitcoin-liquidity/

This week the bitcoin exchange Tradehill launches dark liquidity, or dark pools, for client institutions and individuals that do not want to reveal their trading size and identity. In trading on dark pools, market participants have the ability to execute large block trades without adversely impacting the price in either direction.

Based in San Francisco, Tradehill Inc. has relaunched successfully as a business-to-business bitcoin exchange for institutional investors and individuals qualifying as accredited investors. The original Tradehill founded by CEO Jered Kenna in 2011 had operations in the U.S. and Chile and maintained a consistent second position in daily trading volume after Mt. Gox.

Offering both a transparent open order book and a dark order book, the Tradehill service Prime will be critical for both large investors on the buy side, such as funds and institutions, and commercial participants on the sell side, such as merchant processors and bitcoin mining operators.

As “liquidity” and “market impact” can be synonymous in many cases, the market impact, especially on price, is a key consideration for those larger institutions that are regularly shifting assets between financial markets. If a large trade is executed incorrectly, the market impact can be several percentage points in addition to the typical transaction costs of commission and/or spread.

“Whether you’re trying to sell a large amount of bitcoin above market, or trying to buy without losing your shirt to slippage, dark orders on the Prime platform provide an important tool for larger traders,” said Kenna.
In one week, over 100 new accredited investors signed up for Tradehill Prime. The company requires a $10,000 minimum initial deposit (in bitcoin equivalent or U.S. dollars) and dark orders will be priced in BTC, trading in micro-lots of $1,000. New clients also receive a $75 account credit to test the integrated trading platform on the open order book.

Tradehill is a U.S-based exchange that falls within the definition of FinCEN’s regulations for virtual currency exchange operators. “Bitcoin’s primary use is value transmission and financial technology in the U.S. is a very regulated space,” according to Tradehill COO Ryan Singer. The company has anticipated this regulation and the recent guidance from FinCEN “really helps the startups in the space build a compliance game plan,” he added.

In offering dark pools of bitcoin liquidity within an exchange infrastructure, institutional clients gain the benefits of anonymity and non-display of orders but without losing any of the efficiencies associated with trading on an exchanges’ public order books. With bitcoin, it is difficult to gauge how much large-block trading occurs off a publicly visible exchange. By comparison, research firm Tabb Group estimates that off-exchange and dark pool trading in the U.S. equity markets accounted for 32% of trades in 2012.

Emma Quinn, AllianceBernstein’s Head of Asia Pacific Trading for equities, says ” We use dark pools to access liquidity for orders we would not normally place in the central limit order book. I think dark pools aid price discovery. There has to be post-trade transparency but once that happens you’ve actually got more transparency on a market than you normally would.”

MIT Professor of Finance Haoxiang Zhu agrees with that assessment writing that “dark pools can improve price discovery in open exchanges.” He also said, “Adding a dark pool alongside an exchange tends to concentrate price-relevant information into the exchange and improve price discovery. Improved price discovery coincides with reduced exchange liquidity.”

This is precisely where the Bitcoin market needs to be heading and it is a necessary prerequisite for Bitcoin’s evolving role in global trade. Wholesale trading exchanges like Tradehill Prime represent an evolution from the floating-rate and fixed-rate retail exchanges. They can also be considered a precursor to bitcoin-based forex markets as well as more sophisticated derivatives markets for bitcoin futures and options.