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How Coinbase is making compliance a driver of innovation

By Melissa Strait, Chief Compliance Officer

At Coinbase, we think about compliance a little differently than most companies. Over the coming months, we plan to give the public a look “under the hood” at the programs and technologies we use to keep our customers safe and keep bad actors off our platforms. In addition, we will be publishing a series of research papers that explore some of the biggest challenges that our compliance teams face on a daily basis. The first looks at the misuse of crypto in funding terrorist activities across the globe.

When it comes to innovation, compliance often gets a bad rap. It’s not traditionally seen as driving product innovation — or revenue — and too rarely operates at the bleeding edge of technology. In short, companies often see compliance as a blocker and not an enabler. This perception, paired with an aggressive regulatory and enforcement environment , creates an environment where true innovation and transformation are hard to drive. However, Coinbase is changing that.

Crypto is a highly regulated market. The SEC, CFTC, FinCEN, OFAC, various states and others each oversee different parts of that market. At Coinbase, we’ve prioritized regulatory compliance from the very earliest days of the company. We’ve always believed that for crypto to gain the legitimacy needed for mainstream adoption, compliance can’t be an afterthought — it has to be core to the way we operate. We strongly believe that in order for cryptocurrency to gain widespread acceptance, we must have a constructive relationship with the regulators and agencies that have been charged with oversight of the crypto ecosystem. That trust starts by understanding the principles behind core compliance standards and demonstrating best-in-class efforts to meet or even exceed those standards.

Coinbase’s dedication to compliance is underpinned by a deep sense of care and concern for the health of the global financial ecosystem and the people who participate in it. Our compliance programs detect and prevent financial crime, monitor the health of the market overall, and much more. All this is done for a single reason: to protect our customers.

So how different does compliance in crypto look when compared to a traditional bank or other large financial institution? While crypto aims to create an entirely new and open financial system, compliance with existing regulatory frameworks isn’t an option — it’s a necessity. This means that Coinbase’s compliance team has exactly the same responsibilities as the world’s largest financial institutions when it comes to customer verification, the enforcement of anti-money laundering policies and maintaining internal controls. In fact, many of our programs are modelled on those deployed by the same global retail banks that you probably use on a daily basis.

The very nature of cryptocurrencies nevertheless creates a variety of unique challenges, and, more importantly, opportunities. For instance, the transparent and immutable nature of blockchain transactions makes it far easier and quicker for skilled investigators to track illicit transactions no matter where they occur. This is in stark contrast to the traditional financial system where illicit funds can be difficult to trace because of obfuscation through offshore bank accounts or complex corporate structures that limit transparency and visibility.

Blockchain technology, which underpins crypto, has the promise of creating myriad solutions in financial compliance. Part of the promise of crypto is to bring financial access to the underbanked. This is a demographic that lacks access to basic financial services, such as bank accounts, wire transfers and basic consumer financing options such as mortgages or small business loans. One driver of this issue is the lack of trusted identity documents in certain regions that we take for granted in others. Blockchain technology addresses this issue by enabling the creation and maintenance of unique digital identities which can be ingested by third parties to comply with identity verification requirements. But widespread adoption of this model is still far off unfortunately. Existing regulatory frameworks would likely make it difficult for most institutions to adopt such a model, and regulators may be skeptical of systems where institutions are not either performing Know-Your-Customer checks themselves or independently collecting and having visibility into the identifying information of their customers. Making this process global and not limited to a single country also runs into a complex web of international rules and regulations, further complicating efforts for innovation.

So with all this in mind, Coinbase is in an incredible position: we’ve been able to rethink compliance from the ground up, to build systems and processes that not only meet the compliance requirements for the regions in which we operate, but also build a foundation for the next generation of compliance that takes advantage of all the features that the blockchain has to offer. Over time, it’s our hope that the systems and processes that we’re developing will drive a compliance revolution.

For now, however, at Coinbase, we’re focusing our resources in two main areas: 1) working with our Product, Engineering, and Data Science teams to develop cutting-edge solutions to manage financial crime risk, and 2) developing intelligence that could only be gleaned from the blockchain around current issues in money laundering, terrorist financing, and sanctions that we can share publicly to provide others in the crypto space, regulators and law enforcement agencies.

These types of innovations in compliance, which increase the availability, accessibility, and equity of financial services, are far too important to ignore. We believe that we can demonstrate that new compliance technologies can both safeguard the financial ecosystem from bad actors and introduce new innovations to a critical corner of the industry. It’s time for compliance to get a new reputation: innovator.


How Coinbase is making compliance a driver of innovation was originally published in The Coinbase Blog on Medium, where people are continuing the conversation by highlighting and responding to this story.

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The SEC has told us it wants to sue us over Lend. We don’t know why.

By Paul Grewal, Chief Legal Officer

Last Wednesday, after months of effort by Coinbase to engage productively, the SEC gave us what’s called a Wells notice about our planned Coinbase Lend program. A Wells notice is the official way a regulator tells a company that it intends to sue the company in court. As surprised as we were at the SEC’s threat to sue without ever telling us why, we want to be transparent with you about the course of events leading up to it.

Background

Coinbase has been proactively engaging with the SEC about Lend for nearly six months. We’ve been eager to hear their perspective as we explore innovative ways for our customers to gain more financial empowerment on Coinbase. Specifically for Lend, we’re seeking to allow eligible customers to earn interest on select assets on Coinbase, starting with 4% APY on USD Coin (USDC). We could have simply launched the product but we chose not to. This is far from the norm in our industry. Other crypto companies have had lending products on the market for years, and new lending products continue to launch as recently as last month. But Coinbase believes in the value of open and substantive dialogue with our regulators. So we took Lend to the SEC first.

What we’ve provided to the SEC

Coinbase’s Lend program doesn’t qualify as a security — or to use more specific legal terms, it’s not an investment contract or a note. Customers won’t be “investing” in the program, but rather lending the USDC they hold on Coinbase’s platform in connection with their existing relationship. And although Lend customers will earn interest from their participation in the program, we have an obligation to pay this interest regardless of Coinbase’s broader business activities. What’s more, participating customers’ principal is secure and we’re obligated to repay their USDC on request.

We shared this view and the details of Lend with the SEC. After our initial meeting, we answered all of the SEC’s questions in writing and then again in person. But we didn’t get much of a response. The SEC told us they consider Lend to involve a security, but wouldn’t say why or how they’d reached that conclusion. Rather than get discouraged, we chose to continue taking things slowly. In June, we announced our Lend program publicly and opened a waitlist but did not set a public launch date. But once again, we got no explanation from the SEC. Instead, they opened a formal investigation. They asked for documents and written responses, and we willingly provided them. They also asked for us to provide a corporate witness to give sworn testimony about the program. As a result, one of our employees spent a full day in August providing complete and transparent testimony about Lend. They also asked for the name and contact information of every single person on our Lend waitlist. We have not agreed to provide that because we take a very cautious approach to requests for customers’ personal information. We also don’t believe it is relevant to any particular questions the SEC might have about Lend involving a security, especially when the SEC won’t share any of those questions with us.

State of play & next steps

Despite Coinbase keeping Lend off the market and providing detailed information, the SEC still won’t explain why they see a problem. Rather they have now told us that if we launch Lend they intend to sue. Yet again, we asked if the SEC would share their reasoning with us, and yet again they refused. They have only told us that they are assessing our Lend product through the prism of decades-old Supreme Court cases called Howey and Reves. The SEC won’t share the assessment itself, only the fact that they have done it. These two cases are from 1946 and 1990. Formal guidance from the SEC about how they intend to apply Howey and Reves tests to products like Lend would be a big help to regulating our industry in a responsible way. Instead, last week’s Wells notice tells us that the SEC would rather skip those basic regulatory steps and go right to litigation. They’ve offered us the chance to submit a written defense of Lend, but that would be futile when we don’t know the reasons behind the SEC’s concerns.

The SEC has repeatedly asked our industry to “talk to us, come in.” We did that here. But today all we know is that we can either keep Lend off the market indefinitely without knowing why or we can be sued. A healthy regulatory relationship should never leave the industry in that kind of bind without explanation. Dialogue is at the heart of good regulation.

The net result of all this is that we will not be launching Lend until at least October. Coinbase continues to welcome additional regulatory clarity; mystery and ambiguity only serve to unnecessarily stifle new products that customers want and that Coinbase and others can safely deliver.

We will keep our customers informed at every step as things progress.


The SEC has told us it wants to sue us over Lend. We don’t know why. was originally published in The Coinbase Blog on Medium, where people are continuing the conversation by highlighting and responding to this story.

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Lessons from WhatsApp on international expansion

As part of our mission to increase economic freedom in the world, we’ve been thinking more about how we expand our products internationally. To get 1 billion people using crypto through our products, we will need to have much broader reach in more countries.

I recently caught up with the WhatsApp founders because I wanted to get their perspective on how WhatsApp became so pervasive globally. Almost anywhere you go in the world, even in remote places, you will see billboards and kiosks with businesses listing their WhatsApp number as the main way to contact their business, in addition to individuals using the product regularly. How did they do this? And more importantly, how can Coinbase do for payments what they did for messaging? This is what it will take to build a truly global economy.

Here are the main lessons they shared with me:

1. Develop good global accessibility and empathy

Reduce barriers to entry (such as in onboarding). Instill strong localization that feels natural in native languages. Make the product work seamlessly in adverse environments (low/intermittent network connectivity, old devices, etc). Understand that not everyone is affluent or an expert. Understand that people may use your product differently due to cultural norms (Brazil used a lot of voice messaging, Arabic nations used a lot of broadcast messaging). Learning from your users is key. They will guide you to what to build.

2. Partner with key players

There is an interesting anecdote of WhatsApp history where they signed a global marketing relationship with Nokia. The writing was on the wall for Nokia’s demise but at the same time, they had the marketing heft to put the WhatsApp logo all over the world. It was a big win for WhatsApp. In addition, they signed key deals with phone OEM manufacturers to get WhatsApp pre-installed on a number of devices.

3. Don’t overly fixate on one market

WhatsApp never focused on the US or India or Mexico or Brazil exclusively. They focused on building a global product and global process. Their strategy was more “breadth first” rather than “depth first”.

Conclusion

At Coinbase we will be thinking about these lessons to see how we can further accelerate our ambitious international expansion goals. How could our app perform better in low connectivity environments? What equivalent partnership deals should we be pursuing? How can we reduce friction in onboarding or to make payment? Etc.

There is a piece of the puzzle here for us that is different from WhatsApp: we need the blockchains to scale several orders of magnitude to reach this many users globally. Coinbase to Coinbase transactions are fast (because they’re off chain) today, but on chain transactions are still much too slow. We are spinning up a new Protocol Team of engineers at Coinbase to work on the underlying blockchains, including layer 2 solutions, to see what we can do to help accelerate this.

It will take a number of parts of the company and industry coming together to build a new more fair, free, and efficient financial system for the world. But when we’re successful it will have far reaching implications.


Lessons from WhatsApp on international expansion was originally published in The Coinbase Blog on Medium, where people are continuing the conversation by highlighting and responding to this story.

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Kate Rouch Joins Coinbase as Chief Marketing Officer

By Emilie Choi, President and COO

Former Facebook Global Head of Brand and Product to join Coinbase as Chief Marketing Officer, responsible for all global brand, product and performance marketing efforts.

Today we’re thrilled to welcome Kate Rouch to Coinbase as our new Chief Marketing Officer, overseeing Coinbase’s global brand, product and performance marketing. Kate joins Coinbase after more than a decade at Facebook, most recently serving as Global Head of Brand and Product Marketing for Instagram, WhatsApp, Messenger, Facebook app, Public Affairs and the Facebook company. Kate’s experience at a company with the scale and impact of Facebook will be invaluable as we continue building our brand, growing our teams and working to bring millions more people into the cryptoeconomy.

At Facebook, Kate’s marketing teams were awarded with numerous global advertising awards, including two Silver Lions at Cannes. Throughout her tenure at the company, Facebook’s monthly active users grew from ~500 million to nearly 3 billion people worldwide.

Our industry is at a critical juncture: the crypto community is growing at a rapid pace and crypto companies are more visible to consumers than ever before. At Coinbase alone, we now have more than 68 million customers around the world, with more and more people experiencing first-hand the ways crypto improves upon the traditional financial system.

In Kate’s own words: “I am so inspired by what I’ve learned about crypto, and the vast ecosystem it is helping to usher forth. At its core, Coinbase is about creating more economic freedom for people. It is a mission I feel passionately about. I can’t wait to get started helping to introduce millions more people to the benefits of crypto.”

Welcome to Coinbase, Kate!


Kate Rouch Joins Coinbase as Chief Marketing Officer was originally published in The Coinbase Blog on Medium, where people are continuing the conversation by highlighting and responding to this story.

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How Coinbase responds to industry-wide crypto security threats

It’s not about competition when it comes to crypto security

By Matt Muller, Head of Security Operations, Coinbase

At Coinbase we believe that a healthy and safe crypto industry is critical to growing and maturing the cryptoeconomy. Malicious threats against any crypto business are bad for the industry as a whole, not only Coinbase.

That’s why it’s important to have a community mindset when we see security threats in the wild. As they say, rising tides lift all boats.

Security incidents aren’t unique to crypto but when they happen, the crypto industry has the unique advantage of being able to immediately analyze how stolen funds have moved on the relevant blockchains. This allows us to work with each other to freeze funds and return stolen assets to victims.

Earlier this month, Poly Network, a cross-chain DeFi protocol, and Liquid, a Japanese crypto exchange, reported sophisticated cyberattacks against their platforms. In both of these cases, Coinbase rapidly mobilized our teams to scope the situation, provide analysis and international cross-team collaboration to determine and mitigate the impact on the crypto industry (to be clear neither attack impacted the Coinbase threat platform.)

Coinbase works with industry partners to offer intelligence analysis on attacker tactics, techniques and procedures (TTPs), as well as blockchain analysis. For example, we regularly help connect victims of cyber intrusions (whether crypto exchanges or decentralized finance (DeFi) projects) to the appropriate communication channels with the rest of the virtual asset service provider (VASP) community to make sure swift and decisive action is taken.

Our specific responses depend on the type of attack, but in the case where funds are stolen, Coinbase will:

  • Block any addresses that are identified as a part of the attack from sending funds to Coinbase customers
  • Identify these addresses in our Coinbase Analytics tool (which propagates to internal and external customers of that tool)
  • Track the movement of funds using Coinbase Analytics and other analysis tools
  • Proactively reach out to ecosystem partners for additional information that might be useful in identifying the attacker

Coinbase has built relationships with the compliance, security, and other investigations functions at several exchanges and ecosystem organizations, which has helped create a trusted network of intelligence professionals that benefit from shared information when appropriate.

Sharing intelligence and analysis quickly is the most effective manner of disrupting unauthorized use of crypto exchanges and protecting our collective community of customers. By exchanging information about attacks, we can learn about attackers’ tactics and techniques, which ultimately help us defend Coinbase. Collaboration also improves our relationship with other exchanges for future incidents and helps make the crypto ecosystem more secure.

Although we’ve seen a steady decline in the financial impact of cryptocurrency exchange compromises over the past two years, there are advanced, persistent groups that continue pursuing new targets. By staying vigilant and working together we have successfully countered the actions of bad actors. For example, last September, KuCoin experienced an attack which led to the loss of $281,000,000 in funds. Ultimately, KuCoin was able to recover a large portion of stolen funds by working closely with exchange and asset issuer partners. Similarly, Liquid has already announced that $16,130,000 of the stolen ERC-20 assets have been frozen through collaboration with the cryptocurrency ecosystem.

When it comes to cybersecurity threats, it’s most important that we work together and self-regulate during these events. We encourage all organizations experiencing or suspecting a cyberattack to reach out to our security team at security@coinbase.com, in case we can help with blockchain analysis, incident response and investigation, and attacker attribution/identification.


How Coinbase responds to industry-wide crypto security threats was originally published in The Coinbase Blog on Medium, where people are continuing the conversation by highlighting and responding to this story.

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Our response to a recent editorial from Bloomberg on Congress’s crypto tax proposal

By: Lawrence Zlatkin, Global VP of Tax, Coinbase

As Global Head of Tax for one of the largest crypto exchanges, while I appreciate the Bloomberg Editorial Board’s perspective on the crypto tax provision in the Senate infrastructure bill, I would like to respectfully offer the following critique from a real-world actor in the crypto space. I disagree with the timing and need for the unexpected and new crypto tax provision in the bill and how it was drafted. The best first step would be to issue regulations so that digital asset brokers would be permitted to issue the same third-party reporting that brokerage firms, like Fidelity and Charles Schwab, issue today. It is not a good first step, and certainly not good tax policy, to require non-brokers to report on transactions for people who are not even their customers.

First, some facts —

The IRS already has the authority to require crypto brokers to provide regular reporting of the gains and losses of their customers’ accounts. But they haven’t. For years, the crypto industry has asked for those regulations, and we are still waiting.

The Editorial Board cites the IRS Commissioner’s estimate of the tax gap as $1T to underscore the urgency for including the crypto tax requirement in the infrastructure bill. Meanwhile, Congress’ Joint Committee on Taxation estimates that the crypto tax gap is approximately $28B over 10 years. In effect, crypto is a drop in the bucket when it comes to the tax gap. The Editorial Board neglects to mention this discrepancy, or that neither figure has ever been accompanied with further explanation or additional data. Without supporting data, both figures only serve to create hype and drama.

And while it’s true that the Senate infrastructure bill’s overbroad and unworkable language alarmed us, it also roused a public outcry well beyond the crypto industry. According to public reports, Senate offices were “swamped” with phone calls and emails, with almost 80 thousand people contacting their senators in just a few days. This wave of public advocacy was diverse, ranging from civil liberties organizations like the Electronic Frontier Foundation (EFF) to the Americans for Tax Reform. Social media lit up with citizens from all walks of life protesting this threat to crypto’s future, including non-apparent champions such as TikTok influencers and rock stars.

The Bloomberg Editorial Board says that the IRS needs a broad statute to include non-brokers right now because we don’t know what we don’t know. But why would we impose reporting requirements on intermediaries who are wholly unrelated to brokering a transaction and have no customer relationship? The IRS doesn’t do that outside of crypto and it shouldn’t do that here.

It is disingenuous to suggest that the IRS will take time to issue these regulations and that non-brokers should have no fear of the law until then. Tax policy should be thoughtful and deliberate. Broad overreach is a regulatory mistake. As long as the statute says that software developers, miners, stakers must do the impossible, there is no lawyer who would advise them to risk operating in violation of laws whose penalties for non-compliance would easily bankrupt them. This will harm innovation and stifle the potential of a hugely important technology at its earliest stages of development.

The one thing on which I do agree with the Editorial Board is that the requirements should “apply to entities that can provide the necessary information.” The Editorial Board also should have acknowledged that crypto brokers, like Coinbase, are currently precluded from reporting sales and exchange related information to the IRS. Without a specific legal mandate (such as the IRS regulations), we cannot compromise or disclose customer information to the government.

Now, some suggestions-

  1. “Brokers” of digital assets should be defined as it is understood in the real world today. It is well established that the predominant number of crypto transactions occur with brokers. If Congress decides that it must create a new definition of “broker” within the infrastructure bill for “digital assets,” then it should define brokers as persons who act as middlemen for compensation, with customers as counterparties. This is a traditional definition of broker and would cover entities like Coinbase.
  2. Propose regulations to define the parameters of tax information reporting for crypto. We would welcome the rules of the road so that we can have a meaningful discussion on how it should be introduced and applied in the real world. The IRS has this authority today.
  3. Hold hearings in Congress on tax oversight for crypto so that there is robust debate on the issue. Today, around 60 million Americans own crypto — roughly one-fifth of the entire U.S. population. Those Americans, and the entire crypto ecosystem, deserve more dialogue than midnight provisions inserted at the last minute.
  4. We should not draft legislation that focuses on crypto ghosts that don’t exist now and have no roadmap to exist in the future. If we focus our laws on problems that don’t actually exist, we will erode America’s leadership in crypto. Why chill the industry in its infancy and send it (and the taxes associated with it) offshore?

Coinbase, as the largest U.S. exchange, agrees with the need for information reporting of crypto. We want people to pay all taxes required under the law. We are building systems and protocols for information reporting in response. While we continue to wait on Congress and the IRS to act, we will do our best to provide our customers with the information they need to comply with their personal reporting obligations.

We are rolling out a Tax Center for our customers in the coming month, with the goal of providing education, guidance, support, data, and historical transactional information. It’s hard to do this in practice, and it can’t be done overnight, but we are confident that we will get there and be best in class. Our customers want to be compliant with their tax obligations and have asked for this guidance and support.

We invite meaningful dialogue and discussion to set the appropriate regulatory parameters for our industry. We have offered this at every turn to both legislators and the IRS. The bipartisan leadership demonstrated by Senators Wyden, Lummis, and Toomey in offering their amendment to help resolve this unnecessary confusion underscores exactly how impactful meaningful dialogue can be.


Our response to a recent editorial from Bloomberg on Congress’s crypto tax proposal was originally published in The Coinbase Blog on Medium, where people are continuing the conversation by highlighting and responding to this story.

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2021 Developer Grants Call for Applications

Coinbase’s mission is to increase economic freedom in the world through the crypto-economy. To achieve this, it is essential to develop common infrastructure that is transparent, safe, secure and benefits all participants.

To aid this community effort, in 2020 we launched our Crypto Community Fund, and in 2021 we’ve allocated $2M through Coinbase Giving, our philanthropic arm, to expand the program. Today, we’re officially seeking applications for our 2021 developer grants focused on blockchain developers who contribute directly to a blockchain codebase, or researchers producing white papers addressing one or more of the following themes:

  1. Scalability: Scalability is a huge barrier to adoption. Current development varies between layer 2 protocols, and has different consensus mechanisms and layer 1 structures. While much of this work has high monetary value, we are specifically looking to fund novel approaches and applications which are not so easily monetized (for example, rollups that originate in math/graph theories).
  2. Privacy, Identity and Zero Knowledge research: Financial privacy is a critical and necessary development for a widespread, safe adoption of crypto. In a world where personal privacy is increasingly at risk, we recognize that the public and permanent broadcasting of transaction history can be concerning. We are open to any applications related to this area, but we are particularly interested in development related to composable privacy — privacy preservation which can be combined with smart contract ecosystems. For example, this may lend itself to academic zero knowledge research.
  3. Protocol security, audit research, developer experience, and other foundational infrastructure: The crypto-economy should be safe for all users, and this is only possible when the protocols themselves are verifiably safe. This could take the form of better developer experience, so that common bugs are easier to avoid, better audit tooling, or even work like Solidify, our static analysis tool. To this end, we’re looking for projects which improve the foundational security of contracts, prevent exploits, and otherwise do the needful, inglorious, sometimes non-monetizable work.
  4. Environmental footprint: For the crypto-economy to have a place in the mainstream, it must be sustainable. While there is still much to understand about the scale of impact, there’s no debate that mining is energy-intensive. We’re excited to see applications with innovative solutions to address this generational challenge.
  5. Wild card: If you are working on a foundational improvement and are finding it hard to get funding, we want to hear from you!

Eligibility and Preferences

  • We welcome applications across any blockchain
  • We are open to submissions for any time frame, although our default is year-long grants
  • Our primary focus is to fund initiatives that maximize community benefit (and that is typically harder to monetize) and/or research that advances the industry
  • We seek diversity in applicants and projects
  • Some examples of previous recipients can be found here.

Process

We encourage all blockchain developers and prospective developers to apply for a Crypto Community Fund grant here, by September 15, 2021.

Proposals will be shortlisted by current crypto developers and important community members. Coinbase will make the final decision.

This website contains links to third-party websites or other content for information purposes only (“Third-Party Sites”). The Third-Party Sites are not under the control of Coinbase, Inc., and its affiliates (“Coinbase”), and Coinbase is not responsible for the content of any Third-Party Site, including without limitation any link contained in a Third-Party Site, or any changes or updates to a Third-Party Site. Coinbase is not responsible for webcasting or any other form of transmission received from any Third-Party Site. Coinbase is providing these links to you only as a convenience, and the inclusion of any link does not imply endorsement, approval or recommendation by Coinbase of the site or any association with its operators.


2021 Developer Grants Call for Applications was originally published in The Coinbase Blog on Medium, where people are continuing the conversation by highlighting and responding to this story.

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Coinbase updates investment policy to increase investments in crypto assets

By Alesia Haas, Coinbase Chief Financial Officer

We believe in the cryptoeconomy, a future where economic transactions — buying, selling, spending, earning — will be based on crypto assets. Our products strive to make that vision a reality by making crypto trusted and easy to use for customers around the world.

Today, the majority of Coinbase corporate financial transactions, such as how we pay our vendors, employees, or invest corporate cash, remain heavily weighted in fiat. We’re in a strong position to lead by example and double down on how we can enable crypto adoption and utility, starting with how we operate our business.

Towards that goal, we are announcing a change in our investment policy. We have committed to invest $500M of our cash and cash equivalents. Going forward, we will also allocate 10% of quarterly net income into a diverse portfolio of crypto assets. This means we will become the first publicly traded company to hold Ethereum, Proof of Stake assets, DeFi tokens, and many other crypto assets supported for trading on our platform, in addition to Bitcoin, on our balance sheet.

Our crypto asset investment allocation will be driven by our aggregate custodial crypto balances — meaning our customers will drive our investment strategy. Our investments will be continually deployed over a multi-year window using a dollar cost averaging strategy. We are long term investors and will only divest under select circumstances, such as an asset delisting from our platform. All trades will be executed via our over the counter desk or away from our exchange to avoid any conflict of interest with our customers.

We may increase our allocation over time as the cryptoeconomy matures. We believe that in the future, more and more companies will hold crypto assets on their balance sheet. We hope by incorporating more crypto assets into our own corporate financial practices, we can take another step towards building a more open cryptoeconomy.


Coinbase updates investment policy to increase investments in crypto assets was originally published in The Coinbase Blog on Medium, where people are continuing the conversation by highlighting and responding to this story.

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Coinbase Ventures: Investing for a Decentralized World

By Emilie Choi, Coinbase President and COO

When I joined Coinbase in Spring 2018, I spoke with our founder and CEO, Brian Armstrong, about booting up Coinbase Ventures. Brian said, “Write a blog post about what you intend to do.” I did, sent it to him, and he said, “Looks good.” I said, “Now what?” He said: “Go launch it!”

Just over three years later, Coinbase Ventures has more than 150 investments in our portfolio. These investments include bets across all sorts of compelling areas in crypto, from international plays (Bitso, a Latin American exchange) to crypto tax players (CoinTracker and TaxBit) to marketplaces (Dapper Labs and OpenSea) to infrastructure plays (Spacemesh and Starkware) to decentralized finance, or DeFi (Uniswap and Compound).

Imagine if you were Google or Facebook in the early days and had made investments in some of the most promising emerging internet companies of the time, from Stripe to Shopify. That’s exactly what we’re achieving in the crypto ecosystem via Coinbase Ventures, our investing arm whose structure mirrors our commitment as a company to decentralization — the team, effort, and decision making is decentralized, and we’re investing in companies that are making this decentralized world possible.

Here are some answers to questions I get:

What’s the common theme? Easy. We invest in amazing teams who are executing on the most important new ideas in crypto.

What will success look like? We want the crypto ecosystem to bloom. We don’t solely invest to generate ROI (Return on Investment), but we’re keeping pace with the best VC funds in terms of returns and ultimately, we’re focused on driving innovation that helps us further our mission to increase economic freedom in the world.

Do the companies have to be of strategic interest to Coinbase (M&A, partnership, or other)? Not at all. That can often be a side benefit, but really we want to invest in amazing entrepreneurs and companies that are building the ecosystem, including potential competitors in certain areas.

Do we invest in competitors? Yes! These companies may look competitive to Coinbase from the outset, but these are still-early days of the industry and we’re committed to building out the cryptoeconomy. Also, Coinbase is a multi-product company and competitors of one product can and often are critical partners for another product.

What is Coinbase Ventures’ secret sauce? OK, here’s the real secret. It’s a labor of love. We don’t have any dedicated employees solely responsible for Coinbase Ventures. Shan Aggarwal, our Head of Corp Dev, oversees it in addition to his demanding day job, and we have a group of exceptional, crypto-native employees such as Justin Mart and Ryan Yi, who do this nights and weekends because they love it so much. My theory is that we’re doing so well because of this. We have no LPs (Limited Partners), no committees, no heavy infrastructure, no marketing, nothing. Just a bunch of passionate employees who use their networks, know-how, and love of crypto to find the best players in the space to invest in.


Coinbase Ventures: Investing for a Decentralized World was originally published in The Coinbase Blog on Medium, where people are continuing the conversation by highlighting and responding to this story.

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Ransomware is a scourge, but eliminating cryptocurrencies won’t make it go away

By Philip Martin, Chief Security Officer, Coinbase

The recent high profile ransomware attacks on Colonial Pipeline and food processing giant JBS have led to knee jerk calls to ban cryptocurrencies because the attackers demanded to be paid in Bitcoin. But if cryptocurrency went away tomorrow would ransomware end? In a word, no. Ransomware existed before cryptocurrency was popular and, if cryptocurrency was outlawed tomorrow, criminals would simply seek alternative payment methods, of which there are many.

The rise of ransomware has been horrible to behold. It is one of the rare online crimes where the impact is felt broadly by everyone. Hospitals unable to service patients. Local governments unable to support citizens. Workers losing jobs because their employers go bankrupt.

But blaming crypto for ransomware is like holding email accountable for ransomware because that’s a vector criminals use to infect victims. Neither are the cause of ransomware. What we need to eradicate this scourge is a more nuanced, multi-pronged strategy that gets to the root cause of the problem.

Why it’s getting worse

The growth of ransomware can be attributed to the rate at which companies are shifting critical systems online and the poor level of controls many companies have over their IT systems. When you couple those factors with ransomware gangs operating from foreign jurisdictions with relative impunity and little ability for law enforcement to drive an international response, you get a recipe for trouble.

This has led some pundits to throw up their hands and conclude the only way to fight back is to ban cryptocurrencies. But if cryptocurrencies are banned, attackers will simply fall back to traditional money laundering methods like prepaid gift cards, money-mules, bulk cash smuggling, funnel accounts or requiring air-dropped cash payments.

What’s more, there are many reasons cryptocurrency is good for law enforcement. Talk to law enforcement agents and those prosecuting crimes like this and they’ll tell you that cryptocurrencies are much easier to track than traditional, harder to trace forms of payment, such as cash.

In the world of Bitcoin, while you might not be able to immediately attach a name to a transfer, the whole history of transfers, for every address on the cryptocurrency network, is preserved forever and accessible to all. Law enforcement can use these “digital breadcrumbs” to track spending patterns. Where that cryptocurrency touches an exchange like Coinbase, which collects KYC (Know Your Customer) data for customers, a subpoena or a warrant will get them a real-world identity. That stands in stark contrast to traditional money laundering using cash or commodities.

What we should be doing

If banning use of cryptocurrency isn’t the answer, what is?

  1. Increase global law enforcement focus on ransomware and aggressively prosecute criminals — in the US or overseas — to create a real disincentive for criminals to use ransomware. The creation of a Ransomware and Digital Extortion Task Force by the DOJ was a positive step forward, but genuine investment in prosecutorial resources and continued engagement with our international partners will be key in the fight to ensure there are no safe haven countries for criminals.
  2. In the wake of the Enron scandal, Congress created incentives for public companies to clean up financial controls and reporting via the Sarbanes-Oxley Act. Earlier this year Congress passed the Anti-Money Laundering Act, setting a framework for financial institutions to modernize their technology and improve the sharing of information to combat money laundering and terrorist financing. Congress must play a similar role in creating minimum standards for corporate security reporting and transparency, creating accountability for malfeasance and creating safe harbors for cooperation and information sharing among companies.
  3. Ensure common sense, existing regulations are applied evenly so that certain exchanges aren’t allowed to use jurisdictional arbitrage to avoid implementing KYC/AML programs. Research shows that the majority of illicit Bitcoin flows through a small group of exchanges. Law enforcement and regulators could curb the flow of ransomware-proceeds by enforcing existing regulations on these venues.

That will take time, of course, so in the meantime companies in the trenches should actively review their own security posture and figure out if and how they could recover if attacked. Most companies have backup policies, but few organizations have restore policies or regularly test their ability to restore in a real-world scenario.

Ransomware isn’t going away even if cryptocurrencies are banned. So don’t be tempted by the “easy answer” given it isn’t really an answer at all. Let’s take the bull by the horns and focus on the hard work of putting ransomware in its place.

This piece originally appeared in Morning Consult.


Ransomware is a scourge, but eliminating cryptocurrencies won’t make it go away was originally published in The Coinbase Blog on Medium, where people are continuing the conversation by highlighting and responding to this story.

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