What Happens if All Stablecoin Users Have to Be Identified?

What Happens if All Stablecoin Users Have to Be Identified?

Imagine the following scenario: Sometime in 2021, financial regulators declare that all stablecoin owners must be verified. What would happen to the cryptocurrency ecosystem?

Right now, a large chunk of stablecoin usage is pseudonymous. That is, you or I can hold $20,000 worth of tether or USD coin stablecoins in an unhosted wallet (i.e., not on an exchange) without having to provide our identities to either Tether or Circle, the managers of these stablecoin platforms. We can send this $20,000 along to other users, who can transfer the coins on, who in turn can transfer them on, and no one along this chain needs to unveil themselves.

J.P. Koning, a CoinDesk columnist, worked as an equity researcher at a Canadian brokerage firm and a financial writer at a large Canadian bank. He runs the popular Moneyness blog.

The only point at which stablecoin users have to submit to a Tether or Circle know-your-customer (KYC) process is to redeem stablecoins directly for traditional bank dollars. Or vice versa, to deposit dollars with Tether or Circle and get freshly minted stablecoins.

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In a world where traditional non-blockchain based financial institutions like PayPal, Chase, and Zelle link all payments to names and addresses, stablecoin networks have become a rare moat of digital payments privacy. This has led to some fairly exotic uses for stablecoins.

In Moscow, Chinese gray market clothes vendors trade cash for tether to repatriate profits, writes CoinDesk’s Anna Baydakova. Ukrainian companies that import from Turkey use tether to skirt foreign exchange controls, and a multi-million Ponzi scheme relied on Paxos standard (PAX) for payments. Meanwhile, in the world of decentralized finance (DeFi), unidentifiable computer programs are conducting billions of dollars in unregulated financial transactions using USD coin and other stablecoins.

But will regulators allow this privacy moat to continue to exist? What if, at this very moment, officials working for the Financial Crimes Enforcement Network (FinCEN), the U.S. Treasury’s money laundering watchdog, are plotting how to rein in stablecoin pseudonymity?

Let me speculate about how a potential unveiling might look.

FinCEN could rule that henceforth, if anyone wants to access tether, USD coin, or any other official stablecoin (TrueUSD, Paxos standard, Gemini dollar, Binance USD, HUSD) they will need to apply for a verified stablecoin account. That would mean providing photo ID, proof of address and other information to Tether, Circle or other issuers.

For many existing stablecoin owners, this won’t be a big deal. Professional arbitrageurs who use stablecoins to move value from one centralized exchange to another are probably already KYC’d. And retail clients who keep their stablecoins on an exchange like Binance wouldn’t see any changes because the exchange already verifies their identities anyways.

But given that every transfer would need to have names and addresses associated with it, an unveiling would certainly weigh on gray market uses such as the Chinese traders in Moscow.

With stablecoins getting bigger by the day, regulators probably can’t ignore the issue of pseudonymity forever.

The issuers themselves would be inconvenienced, too. Building infrastructure to collect and verify the identity of all users, and not just the few who redeem or deposit, is expensive. To recoup their costs, issuers like Tether and Circle may consider introducing fees. All of this could render stablecoins less accessible for people who only want to use them for casual remittances.

It is in the world of DeFi that the fallout of a stablecoin unveiling could be felt the most. Real people who own stablecoins can be easily identified. But in DeFi, stablecoins are often deposited into accounts controlled by bits of autonomous code, or smart contracts, which don’t have any underlying owner. It’s not evident how a stablecoin issuer can conduct KYC on a smart contract.

Maker, one of the most popular decentralized tools, contains $350 million USD coins in various user-created vaults. This hoard of stablecoins serves as collateral backing for dai, Maker’s decentralized stablecoin. Another $130 million USD coin is held in a Maker’s peg stability module smart contract. If all stablecoin owners must be identified, it’s not apparent who or what entity would have to undergo a KYC check for this $130 million.

Compound, another popular DeFi tool, currently holds $1.6 billion USD coin and $350 million tether. Lenders can deposit their stablecoins into Compound smart contracts and collect interest from borrowers who draw from the contracts.

Liquidity pools, smart contracts underpinning decentralized exchanges like Uniswap and Curve, also hold large amounts of stablecoins. Curve liquidity pools currently contain $1.25 billion worth USD coin and $450 million worth of tether.

See also: JP Koning – What Tether Means When It Says It’s ‘Regulated’

Under the strictest scenario, stablecoin issuers could be required to cut off any entity that can’t provide a verified name or address. Which means Curve, Maker, and Compound smart contracts would all be prevented from receiving stablecoins.

Given the ecosystem’s reliance on stablecoins, this would come close to breaking it. Compound, Curve and Uniswap might try to adapt by substituting FinCEN compliant stablecoins like USD coin with decentralized ones, say like Maker’s dai stablecoin. Because decentralized stablecoins don’t rely on traditional banks, they are less beholden to FinCEN dictat.

But remember, Maker relies on USD coin collateral to imbue dai with stability. If Maker, like Compound and Curve, can no longer hold USD coin, then dai itself would become less stable. And so the usability of Compound and other protocols relying on dai would suffer.

If we imagine a more dovish scenario, FinCEN might allow for a smart contract exemption. As long as stablecoins are held in a smart contract rather than an externally controlled account, then FinCEN would allow the stablecoin issuer to provide financial services to the smart contract. Much of DeFi could continue on as before.

This option provides a pretty big loophole for bad actors, though. The whole reason for requiring platforms to verify accounts is to prevent them moving illicit funds. If stablecoins held in smart contracts are exempt from KYC obligations, then enterprising individuals will move stablecoins to the smart contract layer and thus stimie FinCEN controls.

A middle-of-the-road scenario is that FinCEN exempts smart contracts from stablecoin KYC, but only if the smart contract itself verifies the identities of all addresses that interact with the contract. So Curve, in this case, would have to set up a customer due diligence program if it wanted to qualify to use stablecoins. Maker would have to vet all vault owners.

Under this scenario, we could imagine DeFi splitting into two. Purely decentralized protocols would avoid stablecoins altogether to avoid subjecting their users to KYC. Not-so-decentralized finance would start to verify users to maintain access to stablecoins.

There are many other potential scenarios. As you can see, this is a complex problem. If FinCEN is indeed exploring the question of stablecoin pseudonymity, I wouldn’t want to be the official tasked with trying to design an appropriate response. Too strict and DeFi may no longer function. Too light and DeFi will continue to pose a money laundering threat.

Diem Stablecoin Prepares for Liftoff With Fireblocks Custody Partnership

Crypto custodian Fireblocks and payments platform First Digital Assets Group are providing connectivity and support to diem, the global stablecoin and payments system formerly known as libra.

Fireblocks and First are providing the digital plumbing to allow financial service providers such as banks, exchanges, payment service providers (PSPs) and eWallets to plug into Diem on day one, the companies said.

Facebook unveiled the libra project in 2019 and almost immediately became embroiled in a whirlwind of regulatory blowback and governmental outrage. The project’s ambitious goal to create a private global stablecoin backed by a basket of fiat currencies threatened to unseat the high echelons of sovereign monetary policy.

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Now, the rebranded diem plans to emerge around the end of this quarter, with a modest minimum viable project based around a U.S. dollar stablecoin.

It will be integrated, via Fireblocks and First, with Diem Association members like Spotify, Farfetch, Lyft, Uber and Shopify. (It’s notable that former Libra Association members PayPal, Mastercard and Visa are busy pursuing their own plans with public cryptocurrencies.)

The streamlined project has bent to the will of regulators and operates on a strict permissioned basis with a specific onboarding process to become a diem virtual asset service provider, or VASP.

“What Fireblocks and First have built allows merchants and payment service providers to use the diem stablecoin as a payment method in a way that’s really integrated,” Michael Shaulov, CEO of Fireblocks, said in an interview. “It’s more or less seamless, like how they would accept Visa, Mastercard or any other form of payment.”

The diem payments system also allows things like refunds, and the stablecoin can be easily changed back into fiat to pay merchants or salaries and so on, Shaulov said. Looking further down the road, the network also includes a sophisticated smart contract language called Move, Shaulov added, which could be used in areas like permissioned decentralized finance (DeFi.)

Shaulov believes diem will still be one of the fundamental projects bringing crypto into the mainstream, despite taking a while to get off the ground and garnering criticism because of its narrowed-down launch product.

Stablecoin RAI launches, a pure, decentralized alternative for DeFi

New Ethereum-backed stablecoin RAI hopes to be the savior of the DeFi sector by providing a truly decentralized stablecoin alternative.

Developed by blockchain startup Reflexer Labs, RAI is not pegged to any fiat currency and its monetary policy is managed by an on-chain, autonomous controller. It’s a fork of Maker’s DAI. RAI co-founder Ameen Soleimani explained:

“RAI is an asset backed only by ETH, governance-minimized, and programmed to maintain its own price stability without needing to peg to an external price reference like the USD.”

Soleimani believes that RAI, which he dubbed “A Money God,” has far greate potential than simply improving the DeFi sector, adding:

“Our aspirations for RAI, however, are more profound — if RAI fulfills its purpose within DeFi and starts to earn global adoption, it could prove to be a viable solution to the Triffin Dilemma, and bring credible neutrality to the administration of a stable global reserve asset.”

The Triffin Dilemma consists of potentially contradictory incentives which arise when an asset, like the USD, serves both as national currency and for international reserves.

Announced today, the asset has launched on the Ethereum blockchain and is available via Uniswap v2, with liquidity mining pools set to be announced in the coming weeks. Prior to a strong liquidity pool, the team admitted that “the controller will be weaker than usual.”

While it’s a stable, it’s not pegged to the value of USD and initially, RAI’s redemption price will be set at $3.14. One immediate use-case in decentralized finance, or DeFi, the team predicts will be a method to avoid liquidation on strong price fluctuations for Ethereum and other cryptocurrencies.

How is RAI different?

Stablecoins like Tether (USDT) are centralized and pegged to US dollars, while even Maker’s DAI accepts centralized stablecoin USDC as collateral. This makes true decentralization finance acolytes concerned as centralized coins can be censored. RAI only uses ETH as collateral.

RAI’s ability to maintain a stable price despite fluctuations in the value of its ETH backing revolves around its PID Controller — a control loop mechanism similar to a car’s cruise control.

The asset has two prices, a redemption price and a market price. When the market price deviates from the redemption price, an interest rate for those who have staked Ethereum is set to oppose the price move, incentivizing users to return RAI to the target price.

Soleimani, who is also the CEO of the crypto cam site SpankChain explained that, “It works kind of like a spring: the further the market price of RAI moves from the target price, the more powerful the interest rate, and the greater the incentive to return RAI to equilibrium.”

Soleimani added that the redemption price, also known as the initial target price, does not really matter because, “RAI only cares about relative stability.”

During the testing phase conducted throughout 2020, which used Proto RAI tokens, the asset’s price managed to maintain a volatility level of 4% or lower with an average price of around $2. During the same period, Ether’s price grew by more than 250%.

Last week, Reflexer Labs announced a $4.14 million series A funding round led by Pantera Capital and Lemniscap. This round was preceded by an investment raise of $1.68 million in August 2020 led by Paradigm.