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	<title>Gary Gensler &#8211; Mark E. Jeftovic is The Bombthrower</title>
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	<title>Gary Gensler &#8211; Mark E. Jeftovic is The Bombthrower</title>
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		<title>Renewed regulatory pressure on Bitcoin is no surprise</title>
		<link>https://bombthrower.com/renewed-regulatory-pressure-on-bitcoin-is-no-surprise/</link>
					<comments>https://bombthrower.com/renewed-regulatory-pressure-on-bitcoin-is-no-surprise/#comments</comments>
		
		<dc:creator><![CDATA[Mark E. Jeftovic]]></dc:creator>
		<pubDate>Thu, 02 May 2024 16:39:11 +0000</pubDate>
				<category><![CDATA[Bitcoin]]></category>
		<category><![CDATA[1099-DA]]></category>
		<category><![CDATA[Consenys]]></category>
		<category><![CDATA[Gary Gensler]]></category>
		<category><![CDATA[Liz Warren]]></category>
		<category><![CDATA[Metamask]]></category>
		<category><![CDATA[monetary apartheid]]></category>
		<category><![CDATA[Operation Chokepoint]]></category>
		<guid isPermaLink="false">https://bombthrower.com/?p=9791</guid>

					<description><![CDATA[The renewed regulatory pressure on Bitcoin comes as no surprise - but in the long run, it won't matter (for those who prepare beforehand).]]></description>
										<content:encoded><![CDATA[<div style="margin-top: 0px; margin-bottom: 0px;" class="sharethis-inline-share-buttons" ></div><p>&nbsp;</p>
<p><img fetchpriority="high" decoding="async" class="aligncenter wp-image-9796" src="https://bombthrower.com/wp-content/uploads/2024/05/ouroboouros-bitcoin-2-1024x585.jpg" alt="" width="859" height="491" /></p>
<h2 style="text-align: center;">Nor will it change anything over the long haul&#8230;</h2>
<p class="p1">We’ve always said that the rise of Bitcoin and non-state fintech was a monetary regime change, and that it would be naive to expect the entrenched “powers that be” and incumbent establishment to go down without a fight.</p>
<p class="p1">After all, the Cantillionaire class has had monopoly control over a magic lever that surreptitiously transferred everybody else’s wealth to themselves for over a century.</p>
<p class="p1">Now, suddenly Prometheus shows up &#8211; in the form of Satoshi &#8211; and gifts humanity with a new magic lever, called asymmetric public-key cryptography. It’s really just math. But it enables every individual on earth to just as magically shield themselves from this embezzlement</p>
<blockquote class="twitter-tweet">
<p dir="ltr" lang="en">If you want to keep your <a href="https://twitter.com/hashtag/Bitcoin?src=hash&amp;ref_src=twsrc%5Etfw">#Bitcoin</a> safe from the government, just make a seed phrase using Jeffrey Epstein’s clients’ names.</p>
<p>That way the FBI will never look for it.</p>
<p>— Walker<img src="https://s.w.org/images/core/emoji/17.0.2/72x72/26a1.png" alt="⚡" class="wp-smiley" style="height: 1em; max-height: 1em;" /> (@WalkerAmerica) <a href="https://twitter.com/WalkerAmerica/status/1783712241361064353?ref_src=twsrc%5Etfw">April 26, 2024</a></p></blockquote>
<p><script async src="https://platform.twitter.com/widgets.js" charset="utf-8"></script></p>
<p class="p1">Even worse for those elites, is that <i>their </i>mechanism for leeching wealth from society accrues to them in fiat currency units that lose their value over time, while all the unwashed plebes making use of this fancy new system are finding their purchasing power <i>increasing</i> over time.</p>
<p class="p1">The Cantillionaires are fighting the inexorable cannibalization of their own purchasing power, owing to the pernicious effects of using debt for money &#8211; while the rising system is being impelled by network effects, power laws, and good ole-fashioned <i>incentives.</i></p>
<p class="p1">For the establishment, the central bankers, career politicians and fiat financiers, it probably all seems a little… <i>unfair.</i></p>
<p class="p1">Which makes it completely unsurprising that whoever among them sees the writing on the wall and refuses to allow themselves to be “orange pilled”, as it were, will dig in and muster all the power, influence and institutionalized <i>corruption </i>at their disposal to try and forestall the prospect of hyper-Bitcoinization.</p>
<p class="p1"><span class="s1"><b>Chokepoint 1.0 </b></span>was an Obama-era initiative, launched in 2013, that set the table for freezing unsanctioned financial players out of the legacy banking system: payday loans, money transfer networks &#8211; and possibly most notably because it ended an industry overnight: online gambling.</p>
<p class="p1"><span class="s1"><b>Chokepoint 2.0</b></span> happened in the wake of the 2021-2022 crypto winter, the fallout from the FTX bankruptcy (along with Celsius, Terra/Luna, and all <i>that)</i>.</p>
<p class="p1">We saw SEC Chairman Gary Gensler fighting off Bitcoin ETFs, the formation of Liz Warren’s “anti-crypto army”, and a coordinated hitjob on crypto-friendly banks &#8211; among them our own Silvergate Bank, which was going swimmingly well until then, but ultimately succumbed. Silvergate was our first, and remains our only total wash-out over the course of The Bitcoin Capitalist.</p>
<p class="p1">One of the chief architects of Chokepoint 2.0, Bharat Ramamurti, was now heading up the CFTC (and we outlined the numerous connections in <a href="https://thebitcoincapitalist.com"><span class="s1">the June ‘23 portfolio update</span></a> &#8211; which we actually titled “<strong>Are We Into Chokepoint 3.0</strong>” at the time).</p>
<p class="p1"><span class="s2"><b>Chokepoint 3.0 </b></span>began to be recognizable in mid-2023; the first time I heard it referenced by name this year was <a href="https://cryptoslate.com/bitcoin-miners-slam-us-government-planned-survey-as-operation-chokepoint-3-0/"><span class="s1">from Riot Blockchain back in February</span></a>, in response to the US government’s planned “survey” of Bitcoin miners’ electricity usage.</p>
<p class="p1">Since the SEC suffered its humiliating loss against Bitcoin in approving spot ETFs, it seems like the tempo of regulatory FUD in the US has <i>increased </i>and is now coming from all sides:</p>
<ul class="ul1">
<li style="list-style-type: none;">
<ul class="ul1">
<li class="li1"><b></b>We <a href="https://thebitcoincapitalist.com"><span class="s1">reported last edition</span></a> that the SEC served a Wells notice on Uniswap.</li>
<li class="li1"><b></b>They’ve since accused Metamask &#8211; the near ubiquitous Web3 browser wallet &#8211; of being an unlicensed securities broker (Consensys, Metamask’s parent company, <a href="https://www.coindesk.com/policy/2024/04/25/consensys-sues-sec-over-unlawful-seizure-of-authority-over-ethereum/"><span class="s1">is now suing the SEC</span></a> alleging “unlawful seizure of authority”.)</li>
<li class="li1"><b></b>The founders, CEO and CTO of the Samourai Wallet &#8211; a self-custody wallet with a built-in coin mixer/anonymizer &#8211; were arrested and charged <a href="https://www.justice.gov/usao-sdny/pr/founders-and-ceo-cryptocurrency-mixing-service-arrested-and-charged-money-laundering"><span class="s1">“with money laundering and unlicenced money transferring offences”</span></a>, according to the release issued by the US Department of Justice.</li>
<li class="li1"><b></b>The FBI just<a href="https://www.ic3.gov/Media/Y2024/PSA240425"><span class="s1"> issued a warning</span></a> to consumers to avoid using KYC-free exchanges:</li>
</ul>
</li>
</ul>
<blockquote>
<p class="p1"><i>“The FBI warns Americans against using cryptocurrency money transmitting services that are not registered as Money Services Businesses (MSB)… avoid cryptocurrency money transmitting services that do not collect know your customer (KYC) information from customers when required.”</i></p>
</blockquote>
<p class="p1">Adding that:</p>
<blockquote>
<p class="p1"><span class="Apple-converted-space">    </span><i>“Using a service that does not comply with its legal obligations may put you at risk of losing access to funds after law enforcement operations target those businesses.”</i></p>
</blockquote>
<p class="p3"><span class="s3">Which is FBI-speak for saying, “</span><b>Not your keys = not your coins”.</b></p>
<ul class="ul1">
<li style="list-style-type: none;">
<ul class="ul1">
<li class="li1"><b></b>On April 26th, <span class="s2"><b>The Depository Trust and Clearing Corporation (DTCC)</b></span> <a href="https://www.dtcc.com/-/media/Files/pdf/2024/4/26/B20002-24.pdf"><span class="s1">announced they were cutting the collateral value of ETFs</span></a> with Bitcoin or crypto exposure <i>to zero, </i>effective April 30th. They also decreased the value of B1-B3<span class="Apple-converted-space">  </span>junk bonds (pushing the “haircut value” from 50% to 70%)</li>
</ul>
</li>
</ul>
<p class="p1">The list goes on, but we’ll expand on a couple more beyond a bullet-point:</p>
<p class="p1">US Treasury Department’s Deputy Secretary Wally Adeyemo <a href="https://www.reuters.com/markets/us/us-treasurys-adeyemo-warns-malign-actors-are-using-virtual-assets-2024-04-09/?utm_medium=Social&amp;utm_source=Twitter"><span class="s1">warned that</span></a> ”terrorist groups will increase their use of virtual currencies and other digital assets”, even though:</p>
<blockquote>
<p class="p1"><i>“While we continue to assess that terrorists prefer to use traditional financial products and services, we fear that without congressional action to provide us with the necessary tools, the use of virtual assets by these actors will only grow…” </i></p>
</blockquote>
<p class="p1">Said differently, and echoing what other US law enforcement agencies and government ministries have been repeatedly saying in their own studies: <span class="s2"><b>criminals and terrorists still prefer using fiat money<i> </i></b></span>&#8211; namely US dollars &#8211; to carry out their activities.</p>
<p class="p1">And yet &#8211; new constitutional powers are somehow necessary to solve a problem that admittedly doesn’t exist.</p>
<p class="p1">Toward those ends we’ve gotten a preview of <i>possible </i>forthcoming tax disclosures regarding digital assets via the US IRS:</p>
<p class="p1">The proposed new 1099-DA tax form to report “Digital Asset Proceeds From Broker Transactions” <a href="https://www.irs.gov/pub/irs-dft/f1099da--dft.pdf"><span class="s1">was released via the IRS website</span></a>:</p>
<p><img decoding="async" class="aligncenter wp-image-9795" src="https://bombthrower.com/wp-content/uploads/2024/05/IRS-form1099-DA-proposed.png" alt="" width="527" height="599" srcset="https://bombthrower.com/wp-content/uploads/2024/05/IRS-form1099-DA-proposed.png 892w, https://bombthrower.com/wp-content/uploads/2024/05/IRS-form1099-DA-proposed-600x682.png 600w, https://bombthrower.com/wp-content/uploads/2024/05/IRS-form1099-DA-proposed-264x300.png 264w, https://bombthrower.com/wp-content/uploads/2024/05/IRS-form1099-DA-proposed-768x873.png 768w" sizes="(max-width: 527px) 100vw, 527px" /></p>
<p>&nbsp;</p>
<p class="p1">Conspicuous by its presence is the checkbox option for “unhosted wallet provider” and we can see it asking for transfer-in wallet addresses and even transaction IDs.</p>
<p class="p1">This is the format of the <i>proposed </i>form, with public comments invited via <a href="https://IRS.gov/FormsComments"><span class="s1">IRS.gov/FormsComments</span></a>; include “NTF 1099-DA” in your response so they know it’s about this &#8211; I encourage our US readers to do so.</p>
<p class="p1">Again, none of this should be any surprise, and we’ve never advocated the use of Bitcoin and crypto to engage in tax evasion. We’ve expected increasing regulations and identity verification on all roads into or out of the crypto-economy.</p>
<p class="p1">When it’s time to take chips off the table (should you choose to do so), you factor in your tax hit and report that accordingly (here in Canada, the Liberal government just hiked the capital gains inclusion rate from 50% to 66.6% &#8211; taking the effective tax hit on cap gains from 25% to 33%: this becomes effective June 27th and absolutely covers Bitcoin and cryptos).</p>
<p class="p1">Also bear in mind that one of our core premises is that wealth is increasingly<em> on a one-way trip into the crypto-economy</em>, and has no intention of ever returning to the fiat system &#8211; which we think has limited timespan. This means the global financial system will inevitably <a href="https://bombthrower.com/jackpot-chronicles-3-the-great-bifurcation/">bifurcate into two separate monetary systems</a>:</p>
<p><strong>A UBI/welfare system running on CBDCs </strong>where money is replaced by social credit scores; under which neo-Feudal serfs plod through lives of quiet desperation, their day-to-day regimens being gamified and optimized for collectivist, &#8220;degrowth&#8221; objectives. &#8220;Emergency socialism&#8221; to use George Gilder&#8217;s term for it.</p>
<p>And <a href="https://bombthrower.com/network-states-a-primer/">a network of <strong>Crypto-anarchy </strong></a>&#8211; marbled throughout this global, neo-Marxist utopia, will be numerous enclaves, micro-sovereignties, city states and even castes where real wealth is held by market participants who are comparatively free to exercise free-will. It&#8217;s &#8220;The Sovereign Invidividual&#8221; scenario, writ large.</p>
<p>Which side of The Great Bifurcation you&#8217;re going to be on is basically up for grabs right now. As we&#8217;ve been reporting in the newsletter (and outlined in my book, when I finally get out this year), retail facing CBDCs are still a ways off &#8211; measured in terms of years.</p>
<p>There is still time to get on the right side of the <a href="https://bombthrower.com/life-in-2033-monetary-apartheid/">coming Monetary Apartheid</a>.</p>
<p><em>Today&#8217;s post was a small excerpt from the May edition of <strong><a href="https://btmedia.to/bt-post">The Bitcoin Capitalist</a></strong> Letter.</em></p>
<p><em>My forthcoming ebook <strong>The CBDC Survival Guide</strong> will give you the tools and the knowledge to navigate coming era of <strong>Monetary Apartheid</strong>. Bombthrower subscribers will get free when it drops (and <strong>The Crypto Capitalist Manifesto</strong> while you wait), <strong><a href="https://bombthrower.com/join-today">sign up today</a></strong>. </em></p>
<p><em>Follow me <a href="https://snort.social/p/npub1elwpzsul8d9k4tgxqdjuzxp0wa94ysr4zu9xeudrcxe2h3sazqkq5mehan">on Nostr</a>, or <a href="https://twitter.com/StuntPope">Twitter.</a></em></p>
<p>&nbsp;</p>
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			</item>
		<item>
		<title>The Rise and Fall of FTX (Part 2 of 3)</title>
		<link>https://bombthrower.com/the-rise-and-fall-of-ftx-part-2-of-3/</link>
					<comments>https://bombthrower.com/the-rise-and-fall-of-ftx-part-2-of-3/#comments</comments>
		
		<dc:creator><![CDATA[Scott Hill]]></dc:creator>
		<pubDate>Sun, 27 Nov 2022 17:44:14 +0000</pubDate>
				<category><![CDATA[Cryptocurrencies]]></category>
		<category><![CDATA[Alameda]]></category>
		<category><![CDATA[Binance]]></category>
		<category><![CDATA[FTT]]></category>
		<category><![CDATA[FTX]]></category>
		<category><![CDATA[Gary Gensler]]></category>
		<category><![CDATA[Gary Wang]]></category>
		<category><![CDATA[Luna]]></category>
		<category><![CDATA[Sam Bankman-Fried]]></category>
		<category><![CDATA[SBF]]></category>
		<category><![CDATA[Terra]]></category>
		<category><![CDATA[Zhu Su]]></category>
		<guid isPermaLink="false">https://bombthrower.com/?p=6225</guid>

					<description><![CDATA[How did FTX grow from a tiny Hong Kong bucket shop into a top three Crypto exchange over the course of just a few years? What was Alameda research and were they ever legitimate? Most importantly, how exactly does an exchange lose track of up to $10 billion worth of customer deposits?]]></description>
										<content:encoded><![CDATA[<div style="margin-top: 0px; margin-bottom: 0px;" class="sharethis-inline-share-buttons" ></div><p>&nbsp;</p>
<p><img decoding="async" class="aligncenter size-full wp-image-6242" src="https://bombthrower.com/wp-content/uploads/2022/11/Extra-SBF-Sleeping-at-Alameda.jpg" alt="" width="700" height="525" srcset="https://bombthrower.com/wp-content/uploads/2022/11/Extra-SBF-Sleeping-at-Alameda.jpg 700w, https://bombthrower.com/wp-content/uploads/2022/11/Extra-SBF-Sleeping-at-Alameda-600x450.jpg 600w, https://bombthrower.com/wp-content/uploads/2022/11/Extra-SBF-Sleeping-at-Alameda-300x225.jpg 300w" sizes="(max-width: 700px) 100vw, 700px" /></p>
<p>Last week we covered the <a href="https://bombthrower.com/wtf-happened-with-ftx-part-1-of-3/">collapse of FTX as it happened</a> but there’s a lot more to the story. How did FTX grow from a tiny Hong Kong bucket shop into a top three Crypto exchange over the course of just a few years? What was Alameda research and were they ever legitimate? Most importantly, how exactly does an exchange lose track of up to $10 billion worth of customer deposits?<span id="more-6225"></span></p>
<p>Most of this material is still an educated guess, but the guessers are out there putting together clues from <a href="https://www.vox.com/future-perfect/23462333/sam-bankman-fried-ftx-cryptocurrency-effective-altruism-crypto-bahamas-philanthropy">private discussions which have been leaked</a>, the <a href="https://www.coindesk.com/policy/2022/11/22/lawyers-detail-the-abrupt-and-difficult-collapse-of-ftx-in-first-bankruptcy-hearing/">bankruptcy proceedings</a> and first hand dealings shared on Crypto Twitter.</p>
<p><em>It’s worth noting that there is a whole deep state angle to this story.</em></p>
<p>I won’t go into it in this article because so little is known <em>(see endnote &#8211; ed.)</em></p>
<p>What we do know is mostly confined to the fact that FTX CEO Sam Bankman-Fried (SBF) was the second largest donor to Democrat political campaigns since 2019. His Co-CEO for part of the FTX Empire, Ryan Salame, was a top 10 donor to the Republican party in the same period.</p>
<p>Sam Bankman-Fried <a href="https://twitter.com/Leerzeit/status/1591067018433908738">met with SEC Chairman Gary Gensler</a> seeking a “no action” letter on an enforcement matter in April, shortly before SBF began pushing the DCCPA, a bill which the Crypto industry mainly saw as a subtle crackdown on <a href="https://twitter.com/alliancedao/status/1582800340520312833">DeFi wrapped in a reasonable sounding regulatory framework</a>.</p>
<p>The biggest question mark is the <a href="https://www.coindesk.com/layer2/2022/11/22/who-is-gary-wang-the-mysterious-co-founder-of-ftx-and-alameda-research/">identity of FTX CTO and co-founder Garry Wang</a>. The man is a ghost with very little online presence and only a handful of photos. Famed short seller <a href="https://www.youtube.com/watch?v=m6bRsRw1ChY">Marc Cohodes</a> is under the impression that Wang is a state actor for the CCP.</p>
<p><em>These questions are important and interesting, but they don’t make for a useful article because of the complete absence of detail.</em></p>
<h2>Alameda Research</h2>
<p>Alameda Research, the market maker or crypto hedge fund founded by SBF in Hong Kong during the bull run of 2017 is the start of the rot. The official story is that the firm was formed from a team of young hotshots who learned to trade at Jane Street, a notoriously secretive global market maker which trades more than $10 trillion in securities volume each year.</p>
<p>In January 2018 as Bitcoin was collapsing, Alameda research were performing the Japan arbitrage trade. They purchased Bitcoin in the US, moved it onto Japanese exchanges and cashed in on the gap between markets. The spread was often as wide as 10%. SBF claimed the firm made $10M on the arbitrage over the course of several weeks.</p>
<p>This was a complicated trade. Japanese capital controls are strict with only Japanese nationals allowed to hold bank accounts, making it extremely difficult to get the money out of Japan and requiring a reasonable level of sophistication and corporate legitimacy to pull off.</p>
<p>Following the Japan arbitrage, Alameda went after the “Kimchi Premium”. This was the same type of arbitrage trade, with Bitcoin on South Korean exchanges worth up to 20% more than Bitcoin on US exchanges. The capital controls were tighter, the ability to set up corporate infrastructure in the nation was more restricted and Bitcoin was in the middle of collapsing making trading the asset much more risky.</p>
<p><em>Some people are suggesting that Alameda lost $10 million on the Kimchi Premium trade, but no one really knows whether any of this story is even true.</em></p>
<p>I’m deeply skeptical of this entire backstory given what we have now seen about how careful SBF is with his public image.</p>
<p><em>It’s entirely possible that this whole story was a fabrication to paint the picture of a boy genius trader with a Jane Street pedigree striking out on his own in Crypto land. </em></p>
<h2>Completely Absurd Fundraising</h2>
<p>In early 2018, Alameda Research established headquarters in Hong Kong. While SBF was a complete unknown to Crypto insiders at the time, Alameda Research was making a name for itself, frequently up the top of the Bitmex trading leaderboard.</p>
<p>Crypto markets in 2018 were very different to the last few years. While 2017 had seen a burst of activity during Bitcoin’s bull run, volumes were still tiny and there were very few professional firms taking the asset class seriously.</p>
<p>It’s completely plausible that in the absence of professional market makers, Alameda Research could have done very well. It also seems likely that the edge that such a small team had would have disappeared quickly as the market became more professional. Alameda Research only had a handful of employees. Nowhere near enough to build and execute a sophistical algorithmic market making strategy, such as those employed at Jane Street.</p>
<p>In December 2019 an <a href="https://twitter.com/donnelly_brent/status/1594711862284898306/photo/1">investment pitch deck for Alameda Research</a> circulated among Crypto insiders. The firm was seeking to raise $200 million in debt funding and was offering 15% payments on the debt. The pitch itself made ridiculous claims about the firm’s edge and was riddled with red flags.</p>
<p><em>“High Returns with no risk &#8211; These loans have no downside”</em></p>
<p>Insiders that viewed the pitch deck were confused. The whispers within the industry were that this firm was highly profitable yet they seemed desperate to raise $200 million. Most stayed away and it’s unclear whether or not the fundraising was successful.</p>
<h2>Launch of FTX</h2>
<p>FTX was founded in May 2019 but had very little volume until the following year when they established the regulatory status to allow US customers to trade. FTX later acquired Blockfolio to obtain additional US licensing and the bones of a trading app. Even with this boost in volume, FTX was considered an unfavorable exchange to make markets for among established industry participants.</p>
<p><em>The presumption was that Alameda Research was an embedded market maker that was given an unfair advantage on the platform and rival firms stayed clear.</em></p>
<p>At the time SBF was still the CEO of both companies. There were claims of a separation of the firms, but it was known that they both operated out of the same offices in Hong Kong. It was rumored that Alameda had full access to customer position data and would hunt for liquidations.</p>
<p><strong><em>FTX was seen as a shady offshore bucket shop.</em></strong></p>
<p>By early 2021 little had changed in the industry perception of FTX, but volume was growing. In January SBF was busy arguing on Twitter, leading to the infamous “I&#8217;ll buy as much Solana as  you have, right now, at $3” <a href="https://twitter.com/SBF_FTX/status/1347964322459262977">tweet</a>. He was not taken seriously until later that year when this huge Solana bet seemed to pay off.</p>
<hr />
<figure id="attachment_6251" aria-describedby="caption-attachment-6251" style="width: 640px" class="wp-caption aligncenter"><a href="https://bitcointimes.com.au"><img loading="lazy" decoding="async" class="wp-image-6251 size-full" src="https://bombthrower.com/wp-content/uploads/2022/11/bitcointimes4.png" alt="" width="640" height="446" srcset="https://bombthrower.com/wp-content/uploads/2022/11/bitcointimes4.png 640w, https://bombthrower.com/wp-content/uploads/2022/11/bitcointimes4-600x418.png 600w, https://bombthrower.com/wp-content/uploads/2022/11/bitcointimes4-300x209.png 300w" sizes="auto, (max-width: 640px) 100vw, 640px" /></a><figcaption id="caption-attachment-6251" class="wp-caption-text"><a href="https://bitcointimes.com.au">Black Friday / Cyber Monday special , use coupon code &#8220;BOMBTHROWER&#8221; gets you a 21,000 sats discount.</a></figcaption></figure>
<hr />
<h2>FTX gains Legitimacy</h2>
<p>By the middle of 2021, with Crypto in a raging bull market and FTX capturing significant market share, the exchange became too large to ignore. A big part of the story was China putting in place another round of Crypto bans in September which forced many major Crypto traders and market makers to find new venues to trade.</p>
<p>Zhu Su, founder of disgraced Crypto Hedge fund Three Arrows Capital <a href="https://twitter.com/zhusu/status/1592382388985683968">said recently</a> that he had moved his fund’s trading from Huobi and Okex to FTX and Binance in the wake of the China ban.</p>
<p><em>FTX gave them extremely favorable terms.</em></p>
<p>A big reason that firms began to feel comfortable with FTX was the splashy fundraising FTX was able to pull off. Market participants assumed that among the billions of dollars of venture capital money that had been invested in FTX, someone had done basic due diligence on the firm. We now know that during these heady days of free money SBF was demanding investment commitments quickly from VCs or he would move on to the next phone call.</p>
<p><em>There was a giant line of VCs desperate to get into an FTX round.</em></p>
<p>The <a href="https://www.crunchbase.com/funding_round/ftx-exchange-series-b--8e9cba4d">July fundraising list</a> was a who’s who of Silicon Valley VC. Led by Sequoia, the round included Softbank, Temasek and VanEck. Apparently none of these firms insisted on even the most basic corporate controls, <a href="https://fortune.com/2022/11/18/ftx-board-investor-chamath-palihapitiya-sam-bankman-fried-board-directors-crypto/">like installing a board of directors</a>. A later round included a strategic investment from Blackrock. FTX was a blue ribbon investment.</p>
<p><em>They all needed Crypto exposure now and FTX was the hottest Crypto startup in town.</em></p>
<p>The other piece of the puzzle was that trading firms were now making money on FTX, when before they were simply getting their positions hunted by Alameda. Leverage was handed out in ample servings. Compliance was lax. Payouts were quick. It seemed to most that FTX had moved on from its shady beginnings to become a legitimate venue for market makers to use.</p>
<h2>Tokens</h2>
<p>A giant part of understanding exactly what went down at FTX is understanding the Tokens they had launched or partnered with. In 2019 FTX launched FTT, an Ethereum ecosystem token which represented a cut of exchange fees and offered discounts to traders for holding it. It was the same model that Binance launched their token with in 2017. Tokens would be bought out of the market with a portion of exchange profits on a regular basis, delivering a return to investors.</p>
<p><em>A huge portion of FTT tokens were held on the FTX balance sheet as an asset.</em></p>
<p>Even more egregious were the Solana ecosystem tokens which FTX helped launch. The <a href="https://www.visualcapitalist.com/ftx-leaked-balance-sheet-visualized/">leaked balance sheet</a> showed that FTX had large holdings of Serum, Maps and Oxy.</p>
<p><em>It showed Serum tokens marked as a $2.2 billion asset. Available market cap at the time was less than $500 million.</em></p>
<p>We don’t know for sure, but it seems likely that loans were taken out backed by FTT and other minor tokens.</p>
<p><strong><em>Essentially, it seems that SBF invented his own currency from this air and then took out US dollar loans against it from anyone that would offer.</em></strong><strong><em> </em></strong></p>
<p>We haven’t heard from any major Crypto lender about whether or not they took FTT as collateral. We may never hear an admission on that point. What we do know is that Solana DeFi, where SBF had significant influence, largely took these minor tokens as collateral for loans on much more generous terms than seems reasonable now.</p>
<p>And why wouldn’t Crypto lenders offer loans to FTX on whatever collateral was offered? FTX was the fastest growing exchange in industry history. It had prestigious investors. Its CEO was throwing around cash on advertising and political donations. Surely FTX was profitable enough to service their loans.</p>
<h2>So what happened to the money?</h2>
<p>When FTX blew up there was a balance sheet hole of somewhere between $6-10 billion. It was reported as “missing customer funds” but judging from recent public comments made by SBF it seems more likely that there was a complex web of loans and cross company funding arrangements than just straight up theft of customer assets.</p>
<p>An underreported part of this story which fills in a key gap is that the offshore FTX entity apparently didn’t have its own bank account. <a href="https://twitter.com/Alice_comfy/status/1593012290647117825">Wires to the offshore exchange would go directly into a bank account held by Alameda Research.</a> It seems that FTX didn’t secretly transfer customer funds to its associated hedge fund, it probably didn’t even make loans between companies.</p>
<p><strong><em>The most likely explanation is that Alameda Research just had direct access to customer funds  which were wired to them. </em></strong></p>
<p>While shocking, it wouldn’t be as egregious if the FTX terms didn’t explicitly <a href="https://twitter.com/krugermacro/status/1592979924381356033">say that assets were held on trust for customers.</a> FTX wasn’t supposed to touch customer funds once they were deposited. Maybe that’s the whole point, that SBF was relying on some bizarre technicality or legal fiction to convince himself that he had the right to deal with customer assets. Did I mention that both of his parents are compliance lawyers, with one a leading expert on tax havens.</p>
<p><em>If there’s anyone that could access the advice to set up a complex piece of legal fiction entitling him to pilfer customer funds in a defensible way, it’s SBF.</em></p>
<p><img loading="lazy" decoding="async" class="aligncenter size-full wp-image-6248" src="https://bombthrower.com/wp-content/uploads/2022/11/Headline-Testifying.png" alt="" width="700" height="466" srcset="https://bombthrower.com/wp-content/uploads/2022/11/Headline-Testifying.png 700w, https://bombthrower.com/wp-content/uploads/2022/11/Headline-Testifying-600x399.png 600w, https://bombthrower.com/wp-content/uploads/2022/11/Headline-Testifying-300x200.png 300w" sizes="auto, (max-width: 700px) 100vw, 700px" /></p>
<h2>Liquidations</h2>
<p>That only explains how Alameda Research got access to customer funds, but how did they lose the funds? Alameda Research is a market maker primarily and was the key integrated market maker on FTX. Among other things that gave Alameda the ability to purchase liquidated positions of customers, likely at a huge discount.</p>
<p>In a bull market this is a hugely advantaged position to be in. Say Bitcoin drops 5% in an hour and longs get liquidated, Alameda was able to purchase those long Bitcoin positions and then resell them later, after the liquidation cascade was over and price had recovered.</p>
<p><em>Alameda was </em><a href="https://twitter.com/Dogetoshi/status/1593233836867194880"><em>exempt from liquidation on FTX</em></a><em>, so they could hold underwater positions for as long as they wanted without being forced to close them. </em><em><br />
</em>In a bear market, Alameda would likely accumulate underwater positions that they couldn’t get out of without incurring a large loss. Other market makers will generally sell a liquidated position off as soon as possible, to avoid being liquidated themselves. This doesn’t appear to be a check and balance that was in place for Alameda’s operations on FTX.</p>
<p>Another key feature of the leverage trading offered at FTX was cross asset collateral. Essentially this means that leverage was offered on the entire portfolio of a customer. There wasn’t a segregation of collateral, users could simply offer up a mixed list of tokens and take margin loans against the whole pie. This included FTT and Serum at much more generous collateral ratios than other exchanges offered.</p>
<p><em>Whatever low quality collateral you had, FTX would take it, and it seems that it would end up on Alameda’s books when a customer was liquidated. </em></p>
<h2>Luna Eclipse</h2>
<p>In a collapsing market, this lack of controls over Alameda is potentially disastrous. Luna had the most high profile collapse in the history of Crypto tokens in May this year, <a href="https://www.coindesk.com/markets/2022/05/12/terras-luna-has-dropped-997-in-under-a-week-thats-good-for-ust/">losing 99.7% of its value in a week</a> before getting as close to absolute zero as possible. FTX and Binance were the major venues for trading the Luna collapse. Traders bought the dip on leverage all the way down.</p>
<p><em>It seems likely that Alameda took all of those liquidated positions onto their own balance sheet.</em></p>
<p>Luna started its collapse at around $90. The following week it was at essentially zero. There is no way that Alameda could have sold off all of those liquidated customer positions as the token collapsed. This type of liquidation transaction is known as “toxic flow” and is a surefire way to bankrupt a market maker.</p>
<p>If FTX’s famously specialized liquidation engine simply meant that customer positions were shunted onto the Alameda balance sheet to be cleared at a later date, then the amount of toxic flow from junk tokens in the last year would build up quickly.</p>
<p>This seems to be the only way the <a href="https://twitter.com/zhusu/status/1590641390069121026">size of the hole</a> makes <a href="https://twitter.com/maxboonen/status/1593937381635153921">any sense</a>.</p>
<h2>Other Problems</h2>
<p>If we assume that Luna blew a giant hole in the balance sheets within the FTX empire then what happened next makes a whole lot more sense. SBF went on a buying spree as Crypto lenders collapsed, backstopping insolvent firms and being proclaimed as <a href="https://www.economist.com/finance-and-economics/2022/07/05/cryptos-last-man-standing">Crypto’s JP Morgan</a>.</p>
<p><em>In the cold light of day a more likely explanation than wanting to save the industry is wanting to save himself.</em></p>
<p>If insolvent Crypto lenders like Voyager and Celsius had given loans to FTX, taking FTT and other minor tokens as collateral then those tokens would be seized and sold into the market during a bankruptcy, cratering the price and liquidating FTX loans with other lenders. Don’t forget, <strong><em>for tokens like Serum, FTX held and likely pledged as collateral more than the entire free float on the market.</em></strong></p>
<p><em>All of this isn’t to say that funds didn’t go missing in other ways though.</em></p>
<p>According to the Bankruptcy filings, <a href="https://hackernoon.com/alameda-loaned-1-billion-to-sam-bankman-fried-and-23-billion-to-paper-bird-inc-aka-sbf-also">FTX had loaned</a> more than $1 billion to SBF individually and $2.3 billion to his investment company, Paper Bird Inc. There were also 9 figure loans to other executives and <a href="https://www.reuters.com/technology/exclusive-bankman-frieds-ftx-parents-bought-bahamas-property-worth-121-mln-2022-11-22/">Bahamas real estate purchased by </a><a href="https://www.reuters.com/technology/exclusive-bankman-frieds-ftx-parents-bought-bahamas-property-worth-121-mln-2022-11-22/">SBF’s</a><a href="https://www.reuters.com/technology/exclusive-bankman-frieds-ftx-parents-bought-bahamas-property-worth-121-mln-2022-11-22/"> parents and associates</a> worth $300 million. There are even suggestions that the $420 million meme fundraise in October 2021 basically just ended up <a href="https://www.wsj.com/articles/ftxs-sam-bankman-fried-cashed-out-300-million-during-funding-spree-11668799774">in the pocket of SBF</a>, rather than productively invested in the company.</p>
<p><img loading="lazy" decoding="async" class="aligncenter size-full wp-image-6247" src="https://bombthrower.com/wp-content/uploads/2022/11/4-Bahamas-Penthouse.png" alt="" width="700" height="469" srcset="https://bombthrower.com/wp-content/uploads/2022/11/4-Bahamas-Penthouse.png 700w, https://bombthrower.com/wp-content/uploads/2022/11/4-Bahamas-Penthouse-600x402.png 600w, https://bombthrower.com/wp-content/uploads/2022/11/4-Bahamas-Penthouse-300x201.png 300w" sizes="auto, (max-width: 700px) 100vw, 700px" /></p>
<p><em>It seems like the FTX balance sheet was used as a slush fund for SBF.</em></p>
<p>None of this in any way can add up to $6-10 billion in stolen customer funds and it’s unlikely that the mechanism was brazen theft. The scenario outlined above, poor trading controls at Alameda creating bad debt within the corporate structure and a CEO that was scrambling to keep the empire afloat, is far more likely. This also casts a new light on the “generous terms” offered to other major market participants in 2021.</p>
<h2>Taking VC money</h2>
<p><strong>What if Alameda’s goal wasn’t to make money, but to lose money to other traders in a perverse growth hack used to attract the next round of “smart money” investors?</strong></p>
<p>After all, at best Alameda had been making a few hundred million from trading over the course of its existence and likely much less than that. As spreads closed with more market makers flooding into the asset class it’s much easier to take money from Sequoia and Softbank than it is to make money trading.</p>
<p><em>Running an unprofitable casino is a terrible business, but selling an unprofitable casino that looks extremely busy to a private investor is a fantastic business.</em></p>
<p>This part of the story seems like the inevitable end state of the 2010s dominance of Venture Capital and private investing. After a decade of easy money, low interest loans and an insatiable appetite for tech investments we were bound to see someone game the system. In 2021 VCs were not doing diligence, they were shoving newly raised funds into startups as fast as possible. <a href="https://news.crunchbase.com/business/global-vc-funding-unicorns-2021-monthly-recap/">Venture capital firms invested $643 billion in 2021</a>. Almost double the pace of 2020 and five times as much as was committed in 2012.</p>
<p><em>For context, noted scam company Theranos raised $1.4 billion over 13 years. FTX raised $1.8 billion in only 3 years.</em></p>
<p>The entire story of the growth of FTX is a story of the driving forces of tech stock investing being applied to Crypto and fintech. The problem is that when a social media company blows up, users just lose their photos and social graph. When a fintech or Crypto company blows up, customers lose their funds and lives are ruined.</p>
<p>A big part of the problem with FTX was that tech growth hacking and the infinite pot of VC money was applied to financial services with little regard for the safety of users. No one did the diligence. The regulators were asleep at the wheel.</p>
<p><em>“Grow fast and break things” isn’t an appropriate model for the financial sector. </em></p>
<h2>We Have Questions&#8230;</h2>
<p>This article mostly dealt with how FTX managed to grow so fast and then blow up so spectacularly but it didn’t touch on the why. As stated in the introduction, there are some major question marks about state entanglement, potential involvement of intelligence operatives and the corruption of captured regulators are all major open questions that I just don’t have answers to.</p>
<p><strong>Was FTX a plant to bring down the Crypto industry and justify tighter regulation?</strong></p>
<p><strong>Was FTX a front for money flowing from Crypto traders and Tech VCs into Democrat coffers?</strong></p>
<p><strong>Why is the <a href="https://www.wsj.com/articles/sam-bankman-frieds-plans-to-save-the-world-went-down-in-flames-11669257574">mainstream media reporting</a> on this event as if SBF is just a failed entrepreneur who dreamed too big, <span style="text-decoration: underline;">rather than a fraud who appropriated customer funds?</span></strong></p>
<p><strong>Who was behind the success of FTX? Who is Gary Wang?</strong></p>
<p><img loading="lazy" decoding="async" class="aligncenter size-full wp-image-6249" src="https://bombthrower.com/wp-content/uploads/2022/11/Extra-Gary-Wang.png" alt="" width="700" height="705" srcset="https://bombthrower.com/wp-content/uploads/2022/11/Extra-Gary-Wang.png 700w, https://bombthrower.com/wp-content/uploads/2022/11/Extra-Gary-Wang-100x100.png 100w, https://bombthrower.com/wp-content/uploads/2022/11/Extra-Gary-Wang-600x604.png 600w, https://bombthrower.com/wp-content/uploads/2022/11/Extra-Gary-Wang-298x300.png 298w, https://bombthrower.com/wp-content/uploads/2022/11/Extra-Gary-Wang-150x150.png 150w" sizes="auto, (max-width: 700px) 100vw, 700px" /></p>
<p>&nbsp;</p>
<p>We likely won’t ever get satisfactory answers to these questions. The family political links between major characters in this story are deeply suspicious. As one <a href="https://twitter.com/AutismCapital/status/1592656282301140992">Crypto Twitter account</a> that has been covering the news relentlessly said:</p>
<p><em>“This FTX fiasco is *really* doing its best to confirm every single conspiracy theory anyone has ever had about anything.”</em></p>
<p>Next week in the conclusion of this three part article I’ll cover some of the fallout surrounding the FTX collapse that is important to understand and the lessons being learned by the industry in its attempt to rebuild.</p>
<h2>Endnote</h2>
<p>[A good place to start down the deep state rabbit hole in all this is Mathew Crawford&#8217;s  &#8216;<a href="https://roundingtheearth.substack.com/p/a-grand-unified-theory-of-the-ftx">A Grand Unified Theory of FTX&#8217;</a> &#8211; which I printed off to read and it clocks in around 65 pages &#8211; markjr]</p>
<p><em>Today’s post is from contributing analyst Scott Hill. To receive further updates of this series and our overall investment thesis for digital assets (even in this climate), <a href="https://bombthrower.com/join">subscribe to the Bombthrower mailing list.</a> </em></p>
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