Bitcoin: Regulations and Legal Risks for a New Virtual Currency
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1 Bitcoin: Regulations and Legal Risks for a New Virtual Currency Presented by: John Casey and Adam Holbrook Copyright 2014 by K&L Gates LLP. All rights reserved.
2 GOALS Learn to speak the Bitcoin language: what is Bitcoin and how does it work? Develop an understanding of current regulatory and legal issues klgates.com 2
3 INTRODUCTION Video klgates.com 3
4 What Is Bitcoin?* *Bitcoin: Questions, Answers, and Analysis of Legal Issues, CONGRESSIONAL RESEARCH SERVICE (Jan. 28, 2015) klgates.com 4
5 THREE FUNDAMENTAL CHARACTERISTICS Digital currency Open source Peer-to-peer (i.e., decentralized) klgates.com 5
6 COMPARISONS TO OTHER CURRENCY No intrinsic value No physical form Not legal tender Not backed by any government or legal entity klgates.com 6
7 How Bitcoin works klgates.com 7
8 HOW DO I GET BITCOIN Exchanges Accept Bitcoin as payment Mine new Bitcoin klgates.com 8
9 DIGITAL WALLETS Store your public address and private key Desktop, mobile, cloud, and paper klgates.com 9
10 A BITCOIN PUBLIC ADDRESS 1F1tAaz5x1HUXrCNLbtMDqcw6o5GNn4xqX klgates.com 10
11 TRANSACTIONS Transferring value between Bitcoin wallets Private key is used to sign transactions Broadcast to the Bitcoin network klgates.com 11
12 BALANCES: THE BLOCK CHAIN Bitcoin s shared public ledger Global verification process klgates.com 12
13 BITCOIN MINING Miners confirm waiting transactions The digital gold rush: rewards for processing klgates.com 13
14 BITCOIN MINING klgates.com 14
15 THE ENTIRE TRANSACTION klgates.com 15
16 WHAT IT REALLY LOOKS LIKE klgates.com 16
17 Why Bitcoin matters klgates.com 17
18 Transaction volume (USD) - 6 months klgates.com 18
19 BENEFITS AND DRAWBACKS Two primary benefits: Lower transaction costs Privacy (pseudonymous, not anonymous) Drawbacks: Not legal tender Still only ~2.5 million wallets Price volatility Network security klgates.com 19
20 PRICE & VOLUME PAST THREE YEARS klgates.com 20
21 DATA BREACHES 2013: Mt. Gox is hacked. 850,000 BTC ($400 million) stolen. 2015: Bitstamp security breach. 19,000 BTC ($5 million) stolen. klgates.com 21
22 BITCOIN GAINING LEGITIMACY Oct. 2013: First Bitcoin ATM installed in B.C : Mainstream websites begin accepting Bitcoin. June 2014: U.S. government auctions almost 30,000 BTC seized from Silk Road. klgates.com 22
23 BITCOIN GAINING LEGITIMACY Nov. 2014: Bitcoin ATM installed in Pioneer Place by local company BitcoinNW. klgates.com 23
24 Legal and Regulatory Issues klgates.com 24
25 IMPORTANT REGULATORY CONCERNS Taxation Illegal money transfers Consumer abuse Bitcoin s effect on the Federal Reserve s ability to meet its objectives klgates.com 25
26 FEDERAL TAXATION Bitcoin received as payment for goods and services: included in gross income. Capital gains and losses apply when Bitcoin is treated as a capital asset. Miners must include new Bitcoin as gross income. klgates.com 26
27 TREASURY DEPARTMENT FinCEN issued guidance in 2013: Bitcoin exchanges are running a money services business - must register, record, and report Recent administrative rulings: A virtual currency trading platform is an MSB. Money transmission between company and seller and company and buyer A company that accepts and converts real currency into Bitcoin for payment is an MSB. Irrelevant that company stored a cache of Bitcoin klgates.com 27
28 2013 SEC ENFORCEMENT ACTION SEC v. Shavers Shavers sold fake Bitcoin-related investments, promising a 1% daily interest return. All transactions were conducted using Bitcoin. SEC alleged violations of Securities Act 17(a) and Rule 10b-5 (fraud in connection with sale of security) and Securities Act 5(a) and 5(c) (offer of securities without a registration statement). klgates.com 28
29 2013 SEC ENFORCEMENT ACTION Bitcoin investments are securities Shavers contested subject-matter jurisdiction because the investments were not securities (e.g., investment contracts). Investment contracts require an investment of money. E.D. Tex.: Bitcoin is a currency or form of money, and investors wishing to invest in BTCST provided an investment of money. klgates.com 29
30 2013 SEC ENFORCEMENT ACTION Summary judgment for the SEC 10b-5 and Securities Act 17(a): Shavers knowingly and intentionally operated his company as a Ponzi scheme, making misrepresentations to investors. Securities Act 5(a) and 5(c): Shavers sold nonexempt securities without registering. Remedy: $40 million disgorgement; civil penalties; and a permanent injunction. klgates.com 30
31 SEC SANCTIONS Illegal operation of exchange: SEC recently sanctioned a computer programmer operating securities exchanges with virtual currency. Exchanges not registered. Programmer barred from the securities industry and subject to penalties. klgates.com 31
32 INVESTMENT ALERTS FINRA Alert (2014): Bitcoin: More than a Bit Risky : Warns of investment risks and risks of fraud. North American Securities Administrators Ass n: Digital currency added to list of top 10 threats to investors in SEC: Alerts in 2013 and 2014 warning of Bitcoin-related Ponzi schemes and risky Bitcoin-related investments. klgates.com 32
33 CONSUMER FINANCIAL PROTECTION BUREAU 2014 Consumer advisory warning: Unclear costs, volatile exchange rates, hacking, and scams. [C]onsumers are stepping into the Wild West when they engage in the market. Now accepting consumer complaints about exchange services and online digital wallets. Threatens enforcement of consumer financial laws. klgates.com 33
34 FEDERAL BANKING REGULATORS No guidance or regulations. Federal Reserve Chair Janet Yellen sees no intersection between Bitcoin and banks. Federal Reserve Bank Examiner Mark Williams presented the top-10 risks associated with Bitcoin: Sovereign attack risk: Bitcoin has the potential to undermine the longstanding bond between sovereign and its currency. klgates.com 34
35 A PEEK AT THE STATES - CALIFORNIA Paving the way: A 2014 law clarified existing law so that virtual currency can be issued and circulated. FinCEN-like regulations: A new bill would require virtual currency businesses to be licensed by the Commission of Business Oversight. $5,000 fee. klgates.com 35
36 A PEEK AT THE STATES NEW YORK Still drafting BitLicense requirements: Sets minimum capital requirements. Companies must store physical addresses of their own customers. Only impacts companies that transmit or store Bitcoin not retailers or miners. klgates.com 36
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