tag:blogger.com,1999:blog-6704573462403312459.comments2024-03-19T07:46:09.811-04:00MoneynessJP Koninghttp://www.blogger.com/profile/02559687323828006535noreply@blogger.comBlogger7063125tag:blogger.com,1999:blog-6704573462403312459.post-14177458136989074162024-03-19T07:46:09.811-04:002024-03-19T07:46:09.811-04:00The US has an incredibly fragmented regulatory str...The US has an incredibly fragmented regulatory structure split between a number of Federal watchdogs and 51 state financial authorities. PayPal itself is regulated by dozens of authorities (see https://www.paypal.com/us/webapps/mpp/licenses). What I think has happened is that the state regulator in charge of PayPal's stablecoin, the New York DFS, is engaging in a bit of regulatory entrepreneurialism by allowing a lite approach to AML compliance.JP Koninghttps://www.blogger.com/profile/02559687323828006535noreply@blogger.comtag:blogger.com,1999:blog-6704573462403312459.post-60656553102144498092024-03-19T04:32:14.899-04:002024-03-19T04:32:14.899-04:00Interesting post. What I don’t understand is how t...Interesting post. What I don’t understand is how the regulator that supervises AML compliance would tolerate PayPal doing this end run? Don’t they have leverage via their role in regulating the rest of PayPal business?Anonymousnoreply@blogger.comtag:blogger.com,1999:blog-6704573462403312459.post-55025876505327671512024-03-14T17:00:38.191-04:002024-03-14T17:00:38.191-04:00A quick update on this...
One of the suggestions ...A quick update on this...<br /><br />One of the suggestions in this post was to use Section 311 on Russian cryptoexchanges that are providing outbound liquidity to ransomware operators.<br /><br />Low and behold, a year and a half later (in early 2023) FinCEN designated a Russian exchange, Bitzlato, under Section 311.<br /><br />https://www.fincen.gov/sites/default/files/shared/Order_Bitzlato_FINAL%20508.pdfJP Koninghttps://www.blogger.com/profile/02559687323828006535noreply@blogger.comtag:blogger.com,1999:blog-6704573462403312459.post-29116530081176510042024-03-14T08:54:18.731-04:002024-03-14T08:54:18.731-04:00Çok güzel bir makale olmuş elinize sağlık Çok güzel bir makale olmuş elinize sağlık şükrüdağhttps://www.blogger.com/profile/15827752038169270410noreply@blogger.comtag:blogger.com,1999:blog-6704573462403312459.post-37313809934430298122024-03-14T08:25:21.708-04:002024-03-14T08:25:21.708-04:00Fair enough. My reason for doing that was to sugge...Fair enough. My reason for doing that was to suggest that it's not the Russian people who are the target. It's the dictator in charge who is the target.JP Koninghttps://www.blogger.com/profile/02559687323828006535noreply@blogger.comtag:blogger.com,1999:blog-6704573462403312459.post-67719655663864792822024-03-13T22:18:12.458-04:002024-03-13T22:18:12.458-04:00I guess my only comment would be on style: It is m...I guess my only comment would be on style: It is more correct to refer to the west being in a sanctions war with Russia, rather than with Putin. The latter formulation seems like it's taken straight from Alinsky (personalize the enemy). Maybe that is good tactics but it's sub-optimal journalism. Anonymousnoreply@blogger.comtag:blogger.com,1999:blog-6704573462403312459.post-52000334612037885072024-03-10T09:36:39.136-04:002024-03-10T09:36:39.136-04:00Personally, i consider the native “coin” of the bl...Personally, i consider the native “coin” of the blockchain to be a newish asset class. Sort of Non-state issued currencies. But I 100% agree that any token built on top of a blockchain using a smart contract can easily be categoried into existing buckets like equities, fixed income, collectibles, etc. they are just assets on a ledger. Anonymousnoreply@blogger.comtag:blogger.com,1999:blog-6704573462403312459.post-34674343045955736002024-03-08T02:45:42.531-05:002024-03-08T02:45:42.531-05:00Even though the vast majority of every digital ass...Even though the vast majority of every digital asset that can be called crypto is either a digital chain letter or has reserves based on it in the background regardless of if it's fixed income or equity, ponzinomics aren't exclusively limited to dogecoin. Social security and the real estate market are both slow ponzi type systems that avoid being popped by merit of piggybacking off the productivity growth of the real economy. Because people are willing to buy back into these markets after a crash due to the digital rules of the fair chain letter system, it no longer has traditional ponzi aspects of quickly self destructing in a permanent fashion. Even if housing is also a ponzi scheme conservative investors are perfectly happy to invest in it since it siphons off other sectors' productive economic output.<br /><br />The difference with crypto is that at least for now, people can largely choose to opt out of it unlike how the more destructive aspects of housing speculation play out on affordability. At least until some idiot bank ends up plowing their customers retirement funds into shit coins, too big to fail plays out, and we end up seeing the absurdity of the government bailing out 420skibiditoilet coin because it's in the top 20 by marketcap.Rothsnoreply@blogger.comtag:blogger.com,1999:blog-6704573462403312459.post-89141348978503684262024-03-07T07:13:24.761-05:002024-03-07T07:13:24.761-05:00Shiba Inu isn't equivalent to a penny stock th...Shiba Inu isn't equivalent to a penny stock tho, it's 11th on CoinGecko -- which makes it a high quality blue chip. Pepe is no slouch, either, at 48th.JP Koninghttps://www.blogger.com/profile/02559687323828006535noreply@blogger.comtag:blogger.com,1999:blog-6704573462403312459.post-25468865415436548812024-03-06T11:38:59.318-05:002024-03-06T11:38:59.318-05:00Yes but who says all of these will find allocation...Yes but who says all of these will find allocations within the crypto part of a portfolio? It's just like penny stocks indeed are 'Equity' - just ones that a good portfolio won't allocate to. Joshuanoreply@blogger.comtag:blogger.com,1999:blog-6704573462403312459.post-68175142670771367722024-03-06T09:18:01.053-05:002024-03-06T09:18:01.053-05:00So Reaganomics restricts MMT? So Reaganomics restricts MMT? Anonymousnoreply@blogger.comtag:blogger.com,1999:blog-6704573462403312459.post-82013086369941468372024-03-06T07:11:36.719-05:002024-03-06T07:11:36.719-05:00Shiba Inu, Dogwifhat, and Pepe on your list, too?Shiba Inu, Dogwifhat, and Pepe on your list, too?JP Koninghttps://www.blogger.com/profile/02559687323828006535noreply@blogger.comtag:blogger.com,1999:blog-6704573462403312459.post-85932069859860945222024-03-06T06:57:36.326-05:002024-03-06T06:57:36.326-05:00"that doesn't belong in the same category..."that doesn't belong in the same category as equity in a company, in my opinion."<br /><br />So let's plunk it into the same category as chain letter assets like doge or floki inu? That makes about as much sense to me as categorizing Microsoft shares into the same bucket as Sergei Mavrodi's MMM scam because they're both deployed on an Oracle database.JP Koninghttps://www.blogger.com/profile/02559687323828006535noreply@blogger.comtag:blogger.com,1999:blog-6704573462403312459.post-73109464687450506892024-03-05T18:42:05.306-05:002024-03-05T18:42:05.306-05:00I’d categorize 100% blockchain native assets like ...I’d categorize 100% blockchain native assets like BTC and ETH as “crypto” in terms of a differentiated enough asset class.Anonymousnoreply@blogger.comtag:blogger.com,1999:blog-6704573462403312459.post-92208633681859102042024-03-05T11:54:38.896-05:002024-03-05T11:54:38.896-05:00i think 'crypto' accurately categorizes th...i think 'crypto' accurately categorizes things that are decentralized (to whatever degree). Maker tokens are equity in a protocol, but that doesn't belong in the same category as equity in a company, in my opinion.byronhttps://www.blogger.com/profile/13113341710014270023noreply@blogger.comtag:blogger.com,1999:blog-6704573462403312459.post-75721848216967785922024-02-26T10:13:54.575-05:002024-02-26T10:13:54.575-05:00What you're describing is a potential way for ...What you're describing is a potential way for banks to get around primary sanctions.<br /><br />But not secondary sanctions, since by clearing dollar (or non-dollar) transactions for Bank B and C, Bank A could potentially lose its access to the New York banking system if caught.JP Koninghttps://www.blogger.com/profile/02559687323828006535noreply@blogger.comtag:blogger.com,1999:blog-6704573462403312459.post-79344707264931140262024-02-26T04:10:21.147-05:002024-02-26T04:10:21.147-05:00Do secondary sanctions prevent large non-Russia de...Do secondary sanctions prevent large non-Russia dealing Turkish bank A clearing dollar transactions internally for small, secretly Russia-dealing Turkish (or otherwise) banks B and C? Turkish bank A remains clean (unless the concept of strict liability is so expansive it includes indirect participation) and retains dollar access. <br /><br />Or would those be tertiary sanctions?<br /><br />Asking for a friend. :-)Anonymousnoreply@blogger.comtag:blogger.com,1999:blog-6704573462403312459.post-4665983417239163362024-02-25T09:33:14.929-05:002024-02-25T09:33:14.929-05:00Great points, Tim.
Just one comment on this:
&qu...Great points, Tim.<br /><br />Just one comment on this:<br /><br />"...the only way to avoid US jurisdiction is to avoid using US Dollars and to use a different currency..."<br /><br />With the new secondary sanctions, using a different currency is not necessarily a way to avoid US jurisdiction.<br /><br />See here: https://ofac.treasury.gov/faqs/1152<br /><br />For example, under primary sanctions, a Turkish bank can still deal with a sanctioned Russian using Turkish lira or some other foreign currency, like yuan. They may even be able to do U.S. dollar transactions for sanctioned Russians, being careful to conduct those on their own books rather than invoking their New York (or Chicago) correspondent bank.<br /><br />Under secondary sanctions, however, our Turkish bank cannot conduct even foreign currency transactions for sanctioned Russians. If they do so and are caught, they could lose their correspondent banking account, and thus their ability to conduct U.S. dollar transactions for the rest of their customers.JP Koninghttps://www.blogger.com/profile/02559687323828006535noreply@blogger.comtag:blogger.com,1999:blog-6704573462403312459.post-3057602522175600822024-02-24T22:42:37.174-05:002024-02-24T22:42:37.174-05:00So one way to avoid the Big Apple is just use BMO....So one way to avoid the Big Apple is just use BMO.Timhttps://www.blogger.com/profile/03894651289037073128noreply@blogger.comtag:blogger.com,1999:blog-6704573462403312459.post-77180825303581516652024-02-24T22:41:23.179-05:002024-02-24T22:41:23.179-05:00To be more technically accurate US Dollar wires ha...To be more technically accurate US Dollar wires have to go through the US at some point. Most of them are processed through New York because that is where most non US banks have there US branch or presence and where most large US banks conduct there correspondent banking operations(even if technically based somewhere else like Wells Fargo or Bank of America are. Hell on paper JPMorgan is based in Ohio and Citibank in South Dakota). However, there are exceptions Bank of Montreal's main US branch is located in Chicago(where BMO's US subsidiary Harris Bank is also headquartered) so a US dollar wire transfer involving BMO will inevitably touch Chicago instead of just New York. BMO also has it's primary US Treasury trading desk in Chicago which also makes BMO one of the few US Treasury Primary Dealers not located in NYC.<br /><br />More broadly the only way to avoid US jurisdiction is to avoid using US Dollars and to use a different currency instead Canadian Dollar, Euro, Japanese Yen, etc. More non Canadian banks than you might think actually do have Canadian correspondent account domiciled in either Toronto or Montreal(BMO has it's intl correspondent unit in Montreal unlike the other Big 5 banks) but the volume of international CAD wires is very small.Timhttps://www.blogger.com/profile/03894651289037073128noreply@blogger.comtag:blogger.com,1999:blog-6704573462403312459.post-34023160359701679652024-02-24T15:48:46.702-05:002024-02-24T15:48:46.702-05:00Thanks for your answer. Thanks for your answer. Anonymousnoreply@blogger.comtag:blogger.com,1999:blog-6704573462403312459.post-65960059831546019562024-02-24T08:12:12.158-05:002024-02-24T08:12:12.158-05:00Thanks, Paul!Thanks, Paul!JP Koninghttps://www.blogger.com/profile/02559687323828006535noreply@blogger.comtag:blogger.com,1999:blog-6704573462403312459.post-88010352526760541422024-02-24T08:12:01.719-05:002024-02-24T08:12:01.719-05:00You're right, most of that is off topic. A few...You're right, most of that is off topic. A few comments on the on topic stuff:<br /><br />"...let's understand what financial sanctions are: they are another tool of soft power of the US Empire."<br /><br />Every advanced nation has a sanctions program. The EU does, as do Canada, Korea, Japan, and China. Even Russia has one too. The difference is that the Americans have the most evolved and effective program.<br /><br />"...but I see another problem, from Iran to Cuba sanctions have hardly killed any regime. Why is that?"<br /><br />I think the best example of a sanctions program working is how they brought Iran to the negotiating table for the JCPOA.<br /><br />"...shift the focus of the search for exchange or reserve assets to something else, be they the Dirham, Bitcoin or gold."<br /><br />There may be some minor substitution into exotic media of exchange. But ultimately the US economy is so dominant, its capital markets so advanced, and the dollar so liquid that there's no escape. Foreign banks will always need a New York correspondent banking account, and that'll always give the US government a tremendous amount of global leverage.JP Koninghttps://www.blogger.com/profile/02559687323828006535noreply@blogger.comtag:blogger.com,1999:blog-6704573462403312459.post-81772077073135670732024-02-23T22:02:45.112-05:002024-02-23T22:02:45.112-05:00Terrific, highly illuminating post, JP.Terrific, highly illuminating post, JP.Paul Blusteinnoreply@blogger.comtag:blogger.com,1999:blog-6704573462403312459.post-44299031611089627012024-02-23T16:51:51.743-05:002024-02-23T16:51:51.743-05:00Ultimately, it's not possible to make US dolla...Ultimately, it's not possible to make US dollar wires that avoid New York. Take the example of Turkey. Turkish banks need to make dollar transfers between each other (or to banks in places like Europe), and that requires going through their New York banker. Two Turkish banks might be able to use a larger Turkish bank where they both have U.S. dollar accounts to conduct a bank-to-bank transfer with each other, temporarily avoiding a direct New York connection, but eventually that larger Turkish bank will be asked to send those dollars elsewhere, and that requires invoking its connection to New York.<br /><br />The big apple can't be evaded. JP Koninghttps://www.blogger.com/profile/02559687323828006535noreply@blogger.com