I've heard that founder of MakerDAO is not strictly against KYC
. I have a message to whole community and specifically to a founder of MakerDAO Rune Christensen. I will explain using concrete examples why having KYC in MakerDAO is a grave mistake and it will lead to MakerDAO fork.
Many people in the first world never actually understand why financial privacy
and financial inclusion
is important. Even people (in the first world) who seemingly supportive of such ideas are not able to provide any concrete examples of why it's actually important.
Unfortunately, I was born in a "wrong" country
(Uzbekistan) and I experienced first hand what financial exclusion actually means. I know first hand that annoying feeling when you read polite, boilerplate rejection letter from financial institution based in first world. So I had to become practical libertarian. I'm going to give you concrete examples of financial discrimination against me
. Then I'm going to explain fundamental reasons why it happens. And finally, I'm going to explain my vision for DAI
Back in 2005, I lived in Uzbekistan. I had an idea to invest in US stocks. I was very naive and I didn't know anything about investing, compliance, bank transfers, KYC etc. All I knew is nice long term charts of US stocks and what P/E means. I didn't contact any US brokerage but I checked information about account opening and how to transfer money there. I approached local bank in Uzbekistan and asked how to transfer money to Bank of New York. Banker's face was like - WOW, WTF?!?! They asked me to go to private room to talk with senior manager. Senior manager of local bank in Uzbekistan asked me why I wanted to transfer money to US. They told me that it's absolutely impossible to transfer money to US/EU and pretty much anywhere. I approached nearly every local bank in the town and they told me the same.
In 2012, I already lived in Moscow and acquired Russian citizenship. I got back to my old idea - investing in US stocks. I called to many US brokerages and all of them politely rejected me. Usually when I called I asked them if I can open an account with them. They told me to hold on line. After long pause, I was able to speak with "senior" support who politely explain me that Russia in their list of restricted countries and they can't open an account for me. Finally, I was able to open an account with OptionsXpress. Next challenge was to convince local Russian bank to transfer money to US. Back then in 2012, I was able to get permission to do so. So you might say - is this happy end?
Fast forwarding US brokerage story to 2017, OptionsXpress was acquired by Charles Schwab. I was notified that my OptionsXpress account will be migrated to Charles Schwab platform. In 2017, I already lived in the Netherlands (but still having Russian citizenship). I wasn't happy with my stupid job in the Netherlands. I called Charles Schwab and asked if I quit my job in the Netherlands and have to return to Russia, what will happen with my account. Schwab told me that they will restrict my account, so I can't do anything except closing my account. So even if I was long term customer of OptionsXpress, Charles Schwab is not fully okay with me.
Going back to 2013, I still lived in Russia. I had another idea. What if I quit my job and build some SAAS platform (or whatever) and sell my stuff to US customers. So I need some website which accept US credit cards. I contacted my Russian bank (who previously allowed me to transfer money to OptionsXpress) about steps to make in order to accept US credit cards in Russia. I've been told explicitly in email that they won't allow me to accept US credit cards under any circumstances.
Back then I still believed in "the free west". So I thought - no problem, I will just open bank account abroad and do all operations from my foreign account. I planned vacation in Hong Kong. And Hong Kong is freest economy in the world. Looks like it's right place to open bank account. I contacted HSBC Hong Kong via email. Their general support assured me that I can open bank account with them if I'm foreigner. I flew to Hong Kong for vacation and visited HSBC branch. Of course, they rejected me. But they recommended me to visit last floor in their HQ building, they told me that another HSBC branch specializes on opening bank accounts for foreigners. I went there and they said minimum amount to open bank account is 10 mil HKD (1.27 mil USD). Later I learned that it's called private banking.
When I relocated to the Netherlands, I asked ABN Amro staff - what's happen with my bank account if I quit/lose my job in the Netherlands and have to return back to Russia. I've been told that I can't have my dutch bank account if I go back to Russia even if I already used their bank for 2+ years.
I still had idea that I would like to quit my job and do something for myself. The problem is that I'm Russian citizen and I don't have any residency which is independent from my employment. So if I quit my job in the Netherlands, I have to return back to Russia. I wanted to see how I would get payments from US/EU customers. I found Stripe Atlas, it's so exciting, they help you to incorporate in US, and even help with banking, all process of receiving credit card payments is very smooth. But as usual in my case, there is a catch - Russia in their list of restricted countries.
Speaking of centralized compliance-friendly (e.g. KYC) crypto exchanges. This year I live and work in Hong Kong. Earlier this year, I thought it would be nice to have an account at local crypto exchange in Hong Kong so I can quickly transfer money from my bank account in Hong Kong to crypto exchange using FPS (local payment system for fast bank transfers). What could go wrong? After all Hong Kong is freest economy in the world, right? I submitted KYC documents to crypto exchange called Weever including copy of my Hong Kong ID as they requested. They very quickly responded that they need copy of my passport as well. I submitted copy of my Russian passport. This time they got silent. After a few days, they sent me email saying that Russia is on the US Office of Foreign Assets Control sanction list, so they just require me to fill a form about source of the funds. I told them that the source of my funds is salary, my Hong Kong bank can confirm that along with my employment contract. They got very silent after I sent them a filled form. After a week of silence I asked them - when my account get approved? They said that their compliance office will review my application soon. And they got very silent again. I waited for two or three weeks. Then I asked them again. And I immediately got email with title - Rejection for Weever Account Opening. And text of email was:
We are sorry to inform you that Weever may not be able to accept your account opening application at this stage.
Exactly the same situation I had with one crypto exchange in Europe back in 2017. Luckily I have accounts at other crypto exchanges including Gemini, one of most compliance obsessed exchange in the world. Although I don't keep my money there because I can't trust them, who knows what might come into head of their compliance officer one sunny day.
By the way, I'm living and working outside of Russia for quite a few years. The situation with crypto exchanges is much worse for those who still living in Russia.
I give you a few other examples of financial discrimination is not related to troubles with my Russian citizenship.
Back in 2018, I still lived in the Netherlands. I logged in into my brokerage account just to buy US ETFs as I always do - SPY and QQQ. I placed my order and it failed to fill. I thought it's just a technical problem with my brokerage account. After a few failed attempts to send buy orders for SPY and QQQ, I contacted their support. What they told me was shocking and completely unexpected. They said I'm not permitted to buy US ETFs anymore as EU resident because EU passed a law to protect retail investors. So as a EU resident I'm allowed to be exposed to more risk by buying individual US stocks but I'm not allowed to reduce my risk by buying SPY because ... EU wants to protect me. I felt final result of new law. By the way, on paper their law looks fine.
And the final example. It's a known fact that US public market become less attractive in recent decades. Due to heavy regulatory burden companies prefer to go public very late. So if successful unicorn startup grows from its inception/genesis to late adoption, company's valuation would be 3-5 orders of orders of magnitude. For example, if valuation of successful company at inception is 1 Mil USD, then at its very latest stage it's valuation would be 10 Bil USD. So we have 10'000 times of growth. In the best case scenario, company would go public at 1 Bil USD 5-10 years before reaching its peak 10 Bil USD. So investors in private equity could enjoy 1000 fold growth and just leave for public only last 10 fold growth stretched in time. In the worst case scenario, company would go public at 10 Bil USD, i.e. at its historical peak. But there are well known platforms to buy shares of private companies, one of such platforms is Forge Global. You can buy shares of almost all blue chip startups. You can even invest in SpaceX! But as always, there is a catch - US government wants to protect not just US citizens but all people in the world (sounds ridiculous, right?). US law requires you to have 1 Mil USD net worth or 200'000 USD annual income if you want to buy shares of non-public company. So if you are high-net worth individual you can be called "accredited investor". Funny thing is that the law intends to protect US citizens but even if you are not US citizen and never even lived in US, this law is still applies to you in practice. So if you are "poor loser", platforms like Forge Global will reject you.
So high-net worth individuals have access and opportunity to Bitcoin-style multi-magnitude growth every 5-10 years. Contrary to private equity markets, US public markets is low risk/low return type of market. If you have small amount of capital, it's just glorified way to protect yourself from inflation plus some little return on top. It's not bad, US public market is a still great way to store your wealth. But I'm deeply convinced that for small capital you must seek fundamentally different type of market - high risk/high return. It's just historical luck that Bitcoin/Ethereum/etc were available for general public from day one. But in reality, viral/exponential growth is happening quite often. It's just you don't have access to such type of markets due to regulatory reasons.
I intentionally described these examples of financial discrimination in full details as I experienced them because I do feel that vast majority of people in the first world honestly think that current financial system works just fine and only criminals and terrorists are banned. In reality that's not true at all. 99.999% of innocent people are completely cut off from modern financial system in the name of fighting against money laundering
Here is a big picture
why it's happening. There are rich countries (so called western world) and poor countries (so called third world). Financial wall is carefully built by two sides. Authoritarian leaders of poor countries almost always want full control over their population, they don't like market economy, and since market forces don't value their crappy legal system (because it works only for close friends of authoritarian leader) they must implement strict capital control. Otherwise, all capital will run away from their country because nobody really respects their crappy legal system. It only has value under heavy gun of government. Only friends of authoritarian leader can move their money out of country but not you.
Leaders of rich countries want to protect their economy from "dirty money" coming from third world. Since citizens of poor countries never vote for leaders of rich countries nobody really cares if rich country just ban everyone from poor country. It's the most lazy way to fight against money laundering - simply ban everyone
from certain country.
Actually if you look deeper you will see that rich countries very rarely directly ban ordinary people from third world. Usually, there is no such law which doesn't allow me to open bank account somewhere in Europe as non-EU resident. What's really happens is that US/EU government implement very harsh penalties for financial institutions if anything ever goes wrong.
So what's actually happens is that financial institutions (banks, brokerages etc) do de-risking
. This is the most important word you must know about traditional financial system!
So if you have wrong passport, financial institution (for example) bank from rich country just doesn't want to take any risks dealing with you even if you are willing to provide full documentation about your finances. It's well known fact that banks in Hong Kong, Europe, US like to unexpectedly shutdown accounts of thousands innocent businesses due to de-risking
So it's actually de-risking
is the real reason why I was rejected so many times by financial institutions in the first world!!! It's de-risking
actually responsible for banning 99.999% of innocent people
. So governments of rich democratic countries formally have clean hands because they are not banning ordinary people from third world directly. All dirty job is done by financial institutions but governments are well aware of that, it's just more convenient way to discriminate. And nobody actually cares! Ordinary citizens in rich countries are never exposed to such problems and they really don't care about people in third world, after all they are not citizens of US/EU/UK/CH/CA/HK/SG/JP/AU/NZ.
And now are you ready for the most hilarious part? If you are big corrupt bureaucrat from Russia you are actually welcome by the first world financial institutions! All Russian's junta keep their stolen money all across Europe and even in US. You might wonder how this is possible if the western financial system is so aggressive in de-risking
Here is a simple equation which financial institution should solve when they decide whether to open an account for you or not: Y - R = net profit
- how much profit they can make with you
- how much regulatory risk
they take while working with you;
That's it! It's very simple equation. So if you are really big junta member from Russia you are actually welcome according to this equation. Banks have special name for serving (ultra) high-net worth individuals, it's called private banking
. It's has nothing to do with the fact that bank is private. It's just fancy name for banking for rich.
So what's usually happen in real world. Some Estonian or Danish bank got caught with large scale money laundering from Russia. European leaders are ashamed in front of their voters. They implement new super harsh law against money laundering to keep their voters happy. Voters are ordinary people, they don't care about details of new regulations. So banks get scared and abruptly shutdown ALL accounts of Russian customers. And European voters are happy. Modern money laundering laws are like shooting mouse in your house using bazooka!
It's very efficient to kill mouse, right?
Now imagine world without financial borders. It's hard to do so because we are all get so used to current status quo of traditional financial system. But with additional effort you can start asking questions - if Internet economy is so global and it doesn't really matter where HQ of startup is located, why they are all concentrated in just a few tiny places like Silicon Valley and ... well, that's mostly it if you count the biggest unicorns!
Another question would be - why so many talented russian, indian, chinese programmers just go to the same places like San Francisco, London and make super rich companies like Amazon, Google, Facebook, Apple to get even richer? If all you need is laptop and access to internet, why you don't see any trade happening between first and third world?
Well actually there is a trade between first and third world but it's not exactly what I want to see. Usually third world countries sell their natural resources through giant corporations to the first world.
So it's possible to get access to the first world market from third world but this access usually granted only to big and established companies (and usually it means not innovative).
Unicorns are created through massive parallel experiment. Every week bunch of new startups are created in Silicon Valley. Thousands and thousands startups are created in Silicon Valley with almost instant access to global market. Just by law of large numbers you have a very few of them who later become unicorns and dominate the world.
But if you have wrong passport and you are located in "wrong" country where every attempt to access global market is very costly, then you most likely not to start innovative startup in the first place. In the best case scenario, you just create either local business or just local copy-paste startup (copied from the west) oriented on (relatively small) domestic market. Obviously in such setup it's predictable that places like Silicon Valley will have giant advantage and as a result all unicorns get concentrated in just a few tiny places.
In the world without financial barriers there will be much smaller gap between rich and poor countries. With low barrier of entry, it won't be a game when winner takes all.
Whole architecture of decentralized
cryptocurrencies is intended to remove middle man and make transactions permissionless
. Governments are inherently opposite to that, they are centralized
. Therefore, decentralized cryptocurrencies are fundamentally incompatible with traditional financial system which is full of middle mans and regulations (i.e. permissions).
Real value of crypto are coming from third world, not the first world. People are buying crypto in rich countries just want to invest. Their financial system and their fiat money are more or less already working for them. So there is no immediate urgency to get rid of fiat money in the first world. So the first world citizens buying crypto on centralized KYCd exchanges are essentially making side bet on the success of crypto in third world. Real and natural environment of cryptocurrencies is actually dark OTC market in places like Venezuela and China.
But cryptocurrencies like Bitcoin and Ethereum have a big limitation to wide adoption in third world - high volatility.
So the real target audience is oppressed (both by their own government and by first world governments) ordinary citizens of third world countries yet they are least who can afford to take burden of high volatility.
Right now, Tether is a big thing for dark markets across the world (by the way, dark market doesn't automatically imply bad!). But Tether soon or later be smashed by US/EU regulators.
The only real and working permissionless stable cryptocurrency (avoiding hyped word - stablecoin) is DAI. DAI
is the currency for post-Tether world to lead dark OTC market around the world
and subvert fiat currencies of oppressive third world governments.
Once DAI become de-facto widespread currency in shadow economy in all of third world, then it will be accepted (after many huge push backs from governments) as a new reality. I'm talking about 10-20+ years time horizon.
But if MakerDAO chooses the route of being compliance friendly then DAI will lose its real target audience (i.e. third world). I can not imagine US/EU calmly tolerate someone buying US stocks and using as a collateral to issue another security (i.e. DAI) which is going to be traded somewhere in Venezuela! You can not be compliance friendly and serve people in Venezuela.
Facebook's Libra was stupidest thing I've seen. It's extremely stupid to ask permission from the first world regulators to serve third world and create borderless economy. Another stupid thing is to please third world governments as well. For example, Libra (if ever run) will not serve Indian, Chinese, Venezuelan people. Who is then going to use stupid Libra? Hipsters in Silicon Valley? Why? US dollars are good enough already.
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