7.
Execution, delivery and process
management
7.1
Documentation; transaction; account
management; reporting; distributor;
supplier
Examples include:
■
data entry errors; accounting errors; failed mandatory reporting; and negligent loss of
client assets (all may affect different aspects of cryptocurrencies – for instance, the
storage of virtual wallets and private and public encryption keys).
Operational Risks in Cryptocurrencies
213
and IP, without a clear means of knowing who operates from these addresses.
Conversely, the peer-to-peer review systems require fully traceable operations so that
anyone can see the balance and the detail of every transaction operated by any address
(testable on biteasy.com). This extensive transparency may not be convenient for
every operator and is dramatically different from the principle of secrecy in banking
operations. Bitcoin users who do not want full disclosure of their operations can
install a transaction system that generates a different address every time a payment is
executed. This makes tracking more difficult for dishonest parties, but would also be
a challenge for the regulator.
Table 19.3 lists some of the mitigating actions for operational risks posed by cryp-
tocurrencies and categorized by risk drivers.
D I S C U S S I O N S O N O P E R A T I O N A L R I S K D R I V E R S
O F C R Y P T O C U R R E N C I E S
This section provides more detail on the vulnerabilities and exposures of crypto-
currencies.
D e c e n t r a l i z e d G o v e r n a n c e a n d R i s k o f C o o r d i n a t e d
A t t a c k s
Because cryptocurrencies operate via a peer-to-peer network, independent of a central
authority or central banks, there is an inherent operational risk linked to decentral-
ization. Although being independent is an appealing feature for many advocates of
cryptocurrencies, decentralization means that functions such as issue, transaction
processing and verification are managed collectively by the network. This creates a
vulnerability to coordinated attacks, which was highlighted already in 2008 by Satoshi
Nakamoto, the putative founder of Bitcoin: “The system is secure as long as honest
nodes collectively control more CPU power than any cooperating group of attackers’
nodes.”
3
This is due to the peer-to-peer review system of transaction validations, where
validating power comes with CPU power, in a system similar to “one-CPU-one-vote.”
Indeed, the confirmation (of not double spending) of transaction requires the knowl-
edge of all previous transactions and their times in order to decide what comes first.
Nakamoto argues: “As long as a majority of CPU power is controlled by nodes that
are not cooperating to attack the network, they will generate the longest chain and
outpace attackers.”
The weakness of this argument is, in our view, the assumption that financial
criminals or other committed agencies would not attempt to outpace genuine
3
Nakamoto, S. (2008) “Bitcoin: a peer-to-peer electronic cash system.”
Consulted
, 1, 2012, 28.
214
RISING OPERATIONAL RISKS
T A B L E 1 9 . 3
Risk drivers of cryptocurrencies such as Bitcoins mapped to
Basel II/III categories
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