In case you haven't noticed the consultation paper
, staff notice
, and report on Quadriga
, regulators are now clamping down on Canadian cryptocurrency exchanges. The OSC and other regulatory bodies are still interested in industry feedback. They have not put forward any official regulation yet. Below are some ideas/insights and a proposed framework.
- This framework was developed through a study of 96 past exchange hack/scam/fraud events. It prevents all historic cases where funds were lost in cryptocurrency exchanges.
- Typical securities frameworks will cost Canadians millions of dollars (ie Sarbanes-Oxley estimated at $5m USD/yr per firm). Implementation costs of this proposal are significantly cheaper.
- Canadians can maintain a diverse set of exchanges, multiple viable business models are still fully supported, and innovation is encouraged while keeping Canadians safe.
Many of you have limited time to read the full proposal, so here are the highlights:
Effective standards to prevent both internal and external theft. Exchange operators are trained and certified, and have a legal responsibility to users.
Regular Transparent Audits
Provides visibility to Canadians that their funds are fully backed on the exchange, while protecting privacy and sensitive platform information.
Establishment of basic insurance standards/strategy, to expand over time. Removing risk to exchange users of any hot wallet theft.
Background and Justifications
Cold Storage Custody/Management
After reviewing close to 100 cases, all thefts tend to break down into more or less the same set of problems:
• Funds stored online or in a smart contract,
• Access controlled by one person or one system,
• 51% attacks (rare),
• Funds sent to the wrong address (also rare), or
• Some combination of the above.
For the first two cases, practical solutions exist and are widely implemented on exchanges already. Offline multi-signature solutions are already industry standard. No cases studied found an external theft or exit scam involving an offline multi-signature wallet implementation. Security can be further improved through minimum numbers of signatories, background checks, providing autonomy and legal protections to each signatory, establishing best practices, and a training/certification program.
The last two transaction risks occur more rarely, and have never resulted in a loss affecting the actual users of the exchange. In all cases to date where operators made the mistake, they've been fully covered by the exchange platforms.
• 51% attacks generally only occur on blockchains with less security. The most prominent cases have been Bitcoin Gold and Ethereum Classic. The simple solution is to enforce deposit limits and block delays such that a 51% attack is not cost-effective.
• The risk of transactions to incorrect addresses can be eliminated by a simple test transaction policy on large transactions. By sending a small amount of funds prior to any large withdrawals/transfers as a standard practice, the accuracy of the wallet address can be validated.
The proposal covers all loss cases and goes beyond, while avoiding significant additional costs, risks, and limitations which may be associated with other frameworks like SOC II.
On The Subject of Third Party Custodians
Many Canadian platforms are currently experimenting with third party custody. From the standpoint of the exchange operator, they can liberate themselves from some responsibility of custody, passing that off to someone else. For regulators, it puts crypto in similar categorization to oil, gold, and other commodities, with some common standards. Platform users would likely feel greater confidence if the custodian was a brand they recognized. If the custodian was knowledgeable and had a decent team that employed multi-sig, they could keep assets safe from internal theft. With the right protections in place, this could be a great solution for many exchanges, particularly those that lack the relevant experience or human resources for their own custody systems.
However, this system is vulnerable to anyone able to impersonate the exchange operators. You may have a situation where different employees who don't know each other that well are interacting between different companies (both the custodian and all their customers which presumably isn't just one exchange). A case study of what can go wrong in this type of environment might be Bitpay, where the CEO was tricked out of 5000 bitcoins
over 3 separate payments by a series of emails sent legitimately from a breached computer of another company CEO. It's also still vulnerable to the platform being compromised, as in the really large $70M Bitfinex hack
, where the third party Bitgo held one key in a multi-sig wallet. The hacker simply authorized the withdrawal using the same credentials as Bitfinex (requesting Bitgo to sign multiple withdrawal transactions). This succeeded even with the use of multi-sig and two heavily security-focused companies, due to the lack of human oversight (basically, hot wallet). Of course, you can learn from these cases and improve the security, but so can hackers improve their deception and at the end of the day, both of these would have been stopped by the much simpler solution of a qualified team who knew each other and employed multi-sig with properly protected keys. It's pretty hard to beat a human being who knows the business and the typical customer behaviour (or even knows their customers personally) at spotting fraud, and the proposed multi-sig means any hacker has to get through the scrutiny of 3 (or more) separate people, all of whom would have proper training including historical case studies.
There are strong arguments both for and against using use of third party custodians. The proposal sets mandatory minimum custody standards would apply regardless if the cold wallet signatories are exchange operators, independent custodians, or a mix of both.
On The Subject Of Insurance
ShakePay has taken the first steps
into this new realm (congratulations). There is no question that crypto users could be better protected by the right insurance policies, and it certainly feels better to transact with insured platforms. The steps required to obtain insurance generally place attention in valuable security areas, and in this case included a review from CipherTrace. One of the key solutions in traditional finance comes from insurance from entities such as the CDIC.
However, historically, there wasn't found any actual insurance payout to any cryptocurrency exchange, and there are notable cases where insurance has not paid. With Bitpay, for example
, the insurance agent refused
because the issue happened to the third party CEO's computer instead of anything to do with Bitpay itself. With the Youbit exchange
in South Korea, their insurance claim was denied
, and the exchange ultimately ended up instead going bankrupt with all user's funds lost. To quote Matt Johnson in the original Lloyd's article
: “You can create an insurance policy that protects no one – you know there are so many caveats to the policy that it’s not super protective.”
ShakePay's insurance was only reported to cover
their cold storage, and “physical theft of the media where the private keys are held”. Physical theft has never, in the history of cryptocurrency exchange cases reviewed, been reported as the cause of loss. From the limited information of the article, ShakePay made it clear their funds are in the hands of a single US custodian, and at least part of their security strategy is to "decline to confirm the custodian’s name on the record". While this prevents scrutiny of the custodian, it's pretty silly to speculate that a reasonably competent hacking group couldn't determine who the custodian is. A far more common infiltration strategy historically would be social engineering, which has succeeded repeatedly. A hacker could trick their way into ShakePay's systems and request a fraudulent withdrawal, impersonate ShakePay and request the custodian to move funds, or socially engineer their way into the custodian to initiate the withdrawal of multiple accounts (a payout much larger than ShakePay) exploiting the standard procedures (for example, fraudulently initiating or override the wallet addresses of a real transfer). In each case, nothing was physically stolen and the loss is therefore not covered by insurance.
In order for any insurance to be effective, clear policies have to be established about what needs to be covered. Anything short of that gives Canadians false confidence that they are protected when they aren't in any meaningful way. At this time, the third party insurance market does not appear to provide adequate options or coverage, and effort is necessary to standardize custody standards, which is a likely first step in ultimately setting up an insurance framework.
A better solution compared to third party insurance providers might be for Canadian exchange operators to create their own collective insurance fund, or a specific federal organization similar to the CDIC. Such an organization would have a greater interest or obligation in paying out actual cases, and that would be it's purpose rather than maximizing it's own profit. This would be similar to the SAFU which Binance has launched, except it would cover multiple exchanges. There is little question whether the SAFU would pay out given a breach of Binance, and a similar argument could be made for a insurance fund managed by a collective of exchange operators or a government organization. While a third party insurance provider has the strong market incentive to provide the absolute minimum coverage and no market incentive to payout, an entity managed by exchange operators would have incentive to protect the reputation of exchange operators/the industry, and the government should have the interest of protecting Canadians.
On The Subject of Fractional Reserve
There is a long history of fractional reserve failures, from the first banks in ancient times, through the great depression (where hundreds of fractional reserve banks failed), right through to the 2008 banking collapse referenced in the first bitcoin block. The fractional reserve system allows banks to multiply the money supply far beyond the actual cash (or other assets) in existence, backed only by a system of debt obligations of others. Safely supporting a fractional reserve system is a topic of far greater complexity than can be addressed by a simple policy, and when it comes to cryptocurrency, there is presently no entity reasonably able to bail anyone out in the event of failure. Therefore, this framework is addressed around entities that aim to maintain 100% backing of funds.
There may be some firms that desire but have failed to maintain 100% backing. In this case, there are multiple solutions, including outside investment, merging with other exchanges, or enforcing a gradual restoration plan. All of these solutions are typically far better than shutting down the exchange, and there are multiple cases where they've been used successfully in the past.
Proof of Reserves/Transparency/Accountability
Canadians need to have visibility into the backing on an ongoing basis.
The best solution for crypto-assets is a Proof of Reserve. Such ideas go back all the way to 2013, before even Mt. Gox. However, no Canadian exchange has yet implemented such a system, and only a few international exchanges (CoinFloor in the UK being an example) have. Many firms like Kraken, BitBuy, and now ShakePay use the Proof of Reserve term to refer to lesser proofs which do not actually cryptographically prove the full backing of all user assets on the blockchain. In order for a Proof of Reserve to be effective, it must actually be a complete proof, and it needs to be understood by the public that is expected to use it. Many firms have expressed reservations about the level of transparency required in a complete Proof of Reserve (for example Kraken here
). While a complete Proof of Reserves should be encouraged, and there are some solutions in the works (ie TxQuick), this is unlikely to be suitable universally for all exchange operators and users.
Given the limitations, and that firms also manage fiat assets, a more traditional audit process makes more sense. Some Canadian exchanges (CoinSquare, CoinBerry) have already subjected themselves to annual audits. However, these results are not presently shared publicly, and there is no guarantee over the process including all user assets or the integrity and independence of the auditor. The auditor has been typically not known, and in some cases, the identity of the auditor is protected by a NDA. Only in one case (BitBuy) was an actual report generated and publicly shared
. There has been no attempt made to validate that user accounts provided during these audits have been complete or accurate. A fraudulent fractional exchange, or one which had suffered a breach they were unwilling to publicly accept (see CoinBene
), could easily maintain a second set of books for auditors or simply exclude key accounts to pass an individual audit.
The proposed solution would see a reporting standard which includes at a minimum - percentage of backing for each asset relative to account balances and the nature of how those assets are stored, with ownership proven by the auditor. The auditor would also publicly provide a "hash list", which they independently generate from the accounts provided by the exchange. Every exchange user can then check their information against this public "hash list". A hash is a one-way form of encryption, which fully protects the private information, yet allows anyone who knows that information already to validate that it was included. Less experienced users can take advantage of public tools to calculate the hash from their information (provided by the exchange), and thus have certainty that the auditor received their full balance information. Easy instructions can be provided.
Auditors should be impartial, their identities and process public, and they should be rotated so that the same auditor is never used twice in a row. Balancing the cost of auditing against the needs for regular updates, a 6 month cycle likely makes the most sense.
Hot Wallet Management
The best solution for hot wallets is not to use them. CoinBerry reportedly uses multi-sig
on all withdrawals, and Bitmex is an international example known for their structure devoid of hot wallets.
However, many platforms and customers desire fast withdrawal processes, and human validation has a cost of time and delay in this process.
A model of self-insurance or separate funds for hot wallets may be used in these cases. Under this model, a platform still has 100% of their client balance in cold storage and holds additional funds in hot wallets for quick withdrawal. Thus, the risk of those hot wallets is 100% on exchange operators and not affecting the exchange users. Since most platforms typically only have 1%-5% in hot wallets at any given time, it shouldn't be unreasonable to build/maintain these additional reserves over time using exchange fees or additional investment. Larger withdrawals would still be handled at regular intervals from the cold storage.
Hot wallet risks have historically posed a large risk and there is no established standard to guarantee secure hot wallets. When the government of South Korea dispatched security inspections to multiple exchanges, the results were still that 3 of them got hacked after the inspections
. If standards develop such that an organization in the market is willing to insure the hot wallets, this could provide an acceptable alternative. Another option may be for multiple exchange operators to pool funds aside for a hot wallet insurance fund. Comprehensive coverage standards must be established and maintained for all hot wallet balances to make sure Canadians are adequately protected.
Current Draft Proposal
(1) Proper multi-signature cold wallet storage.
(a) Each private key is the personal and legal responsibility of one person - the “signatory”. Signatories have special rights and responsibilities to protect user assets. Signatories are trained and certified through a course covering (1) past hacking and fraud cases, (2) proper and secure key generation, and (3) proper safekeeping of private keys. All private keys must be generated and stored 100% offline by the signatory. If even one private keys is ever breached or suspected to be breached, the wallet must be regenerated and all funds relocated to a new wallet.
(b) All signatories must be separate background-checked individuals free of past criminal conviction. Canadians should have a right to know who holds their funds. All signing of transactions must take place with all signatories on Canadian soil or on the soil of a country with a solid legal system which agrees to uphold and support these rules (from an established white-list of countries which expands over time).
(c) 3-5 independent signatures are required for any withdrawal. There must be 1-3 spare signatories, and a maximum of 7 total signatories. The following are all valid combinations: 3of4, 3of5, 3of6, 4of5, 4of6, 4of7, 5of6, or 5of7.
(d) A security audit should be conducted to validate the cold wallet is set up correctly and provide any additional pertinent information. The primary purpose is to ensure that all signatories are acting independently and using best practices for private key storage. A report summarizing all steps taken and who did the audit will be made public. Canadians must be able to validate the right measures are in place to protect their funds.
(e) There is a simple approval process if signatories wish to visit any country outside Canada, with a potential whitelist of exempt countries. At most 2 signatories can be outside of aligned jurisdiction at any given time. All exchanges would be required to keep a compliant cold wallet for Canadian funds and have a Canadian office if they wish to serve Canadian customers.
(2) Regular and transparent solvency audits.
(a) An audit must be conducted at founding, after 3 months of operation, and at least once every 6 months to compare customer balances against all stored cryptocurrency and fiat balances. The auditor must be known, independent, and never the same twice in a row.
(b) An audit report will be published featuring the steps conducted in a readable format. This should be made available to all Canadians on the exchange website and on a government website. The report must include what percentage of each customer asset is backed on the exchange, and how those funds are stored.
(c) The auditor will independently produce a hash of each customer's identifying information and balance as they perform the audit. This will be made publicly available on the exchange and government website, along with simplified instructions that each customer can use to verify that their balance was included in the audit process.
(d) The audit needs to include a proof of ownership for any cryptocurrency wallets included. A satoshi test (spending a small amount) or partially signed transaction both qualify.
(e) Any platform without 100% reserves should be assessed on a regular basis by a government or industry watchdog. This entity should work to prevent any further drop, support any private investor to come in, or facilitate a merger so that 100% backing can be obtained as soon as possible.
(3) Protections for hot wallets and transactions.
(a) A standardized list of approved coins and procedures will be established to constitute valid cold storage wallets. Where a multi-sig process is not natively available, efforts will be undertaken to establish a suitable and stable smart contract standard. This list will be expanded and improved over time. Coins and procedures not on the list are considered hot wallets.
(b) Hot wallets can be backed by additional funds in cold storage or an acceptable third-party insurance provider with a comprehensive coverage policy.
(c) Exchanges are required to cover the full balance of all user funds as denominated in the same currency, or double the balance as denominated in bitcoin or CAD using an established trading rate. If the balance is ever insufficient due to market movements, the firm must rectify this within 24 hours by moving assets to cold storage or increasing insurance coverage.
(d) Any large transactions (above a set threshold) from cold storage to any new wallet addresses (not previously transacted with) must be tested with a smaller transaction first. Deposits of cryptocurrency must be limited to prevent economic 51% attacks. Any issues are to be covered by the exchange.
(e) Exchange platforms must provide suitable authentication for users, including making available approved forms of two-factor authentication. SMS-based authentication is not to be supported. Withdrawals must be blocked for 48 hours in the event of any account password change. Disputes on the negligence of exchanges should be governed by case law.
Continued review of existing OSC feedback is still underway. More feedback and opinions on the framework and ideas as presented here are extremely valuable. The above is a draft and not finalized.
The process of further developing and bringing a suitable framework to protect Canadians will require the support of exchange operators, legal experts, and many others in the community. The costs of not doing such are tremendous. A large and convoluted framework, one based on flawed ideas or implementation, or one which fails to properly safeguard Canadians is not just extremely expensive and risky for all Canadians, severely limiting to the credibility and reputation of the industry, but an existential risk to many exchanges.
The responsibility falls to all of us to provide our insight and make our opinions heard on this critical matter. Please take the time to give your thoughts.
Thank you for participating in the AMA session with Pundi X co-founder and CEO Zac Cheah.
For those of you who may have missed it, the live recording of the AMA session held on July 3 at 10:00 am GMT+8, tackling Q2 progress and addressing questions and concerns by the community members, can be viewed here. A side note that today’s AMA video quality and setting was not ideal. We acknowledge this situation and will make improvement for our next AMA session.
You may also find a summary of the Q2 progress presentation as well as all the detail Q&A below.
## Pundi X Q2 2019 Highlights
* Pundi X has integrated more public chains into our products. In Q2, we completed integration of Binance Chain. NEM chain is in the work. As of today we’ve launched BNB, the Binance Chain native Coin and XEM, NEM native coin on Pundi X payment platform. We will integrate at least one more public chain in Q3.
* The transactions on XPOS for Q2 is 15.5 million in USD, which is close to 300% quarterly growth. The number of transactions is 29,367, which leads to a 11% growth QoQ.
* XPOS has successfully received FCC and KC certifications. A new certification for Latin American market is on the way. * To expand XPOS footprint, Pundi X’s integration with a new leading mainstream point-of-sales device is in the work. Stay tuned for the announcement.
* Pundi X Open Platform was launched in May, 2019, which now supports ERC20 and BEP2 token listing. Moving forward, we will continue to support tokens from other public chains.
* A 3,000 XPASS order from DigiX, a gold-based token, and a 10,000 XPASS order from BitCobie this quarter.
* XPOS is spread in use in over 30 countries. We’ve published a map of XPOS location of self-report XPOS merchant directory. You can find a list of selected XPOS merchants at [https://www.pundix.com/products\](https://www.pundix.com/products)
. * The QoQ growth of XWallet is tremendous at 43%. In the previous quarter, we have less than 20k users, whereas in Q2 we have hit 297k XWallet users. More updates on XWallet:
* Supported BNB and NEM tokens; 2FA, face ID, and optimized SMS serviceAvailable on iOS, Android as well as in Samsung Galaxy Store
New features coming up in Q3:- DApp integration - Decentralized wallet- In-app crypto payments - Chat service, which will be compatible with a commonly used chat app- f(x) testnet features to be rolled out first in XWallet
## Other notices coming up in Q3 2019
* The Q2 token removal will take place on July 14, 2019, which will involve in total 34 billion of NPXS and NPXSXEM (22 million worth in USD) removal. In the past 365 days, we’ve removed a total of 36.1 million US dollar worth of NPXS and NPXSXEM.
Before Q2 removal, the total supply of NPXS ERC20 is 266,962,422,906.53 and NPXSXEM is 95,816,218,929. [See Q1 removal here.](/pundix/recap-of-ama-with-zac-on-july-3-and-q2-report-a23de165dd28)
* [NPXSXEM will be ported to Binance Chain from July 20](/pundix/npxsxem-will-be-on-binance-chain-c6485f17726b). * XPhone pre-order will start in late July with a new product name. Stay tuned. Check out the teaser video that we are releasing it across our communication channels. ## Q&A ## On XPOS
* **Where are we on official global location of XPOS?**
Zac: We have made a map on our official website that merchants can self report and feature their locations. It’s at [https://www.pundix.com/product\](https://www.pundix.com/product)
. We’ll be increasing and updating the map once we have permission form the merchants to update their locations.
* **The marketing from pundi has shifted from 100,000–700,000 xpos units by 2021 to 100,000. I understand the bear market has affected this but please share the strategy moving forward to hit your goal. How do you feel about hitting this goal?**
Zac: The 100K XPOS target has always been the initial goal and it’s stated in our whitepaper. And we are still working on achieving the goal by the end of 2021. Part of our growth strategy is to also explore the possibility to port our platform to traditional POS manufacturers to increase the adoption, which is ongoing at the moment.
* **1 year ago you sent 5000 XPOS somewhere. When, at least half of them, will be working? 3 year target was 100,000 by 2021. Now we have only 150 units, how do you expect to reach this goal?**
Zac: Yes, we have shipped thousands of XPOS to over 30 countries in the world. The 150 you’ve mentioned are the featured merchants which are published on the map. The active XPOS devices are deployed over 33 countries and we are actively talking to B2B partners to have higher wholesale and big deployments.
* **How many XPOS are live and used?**
Zac: We have gone through a very serious bear market, and some of the initial inbound requests for XPOS are not delivered. However, we are working slowly but surely with our Business Development team to not just roll-out into individual buyers, such as what we did on Pizza Day, but also to B2B partners. With the certifications approved, that will also help us to officially roll out to some of the key markets.
Individual merchants can use XWallet collection feature to accept crypto payment with QR code. For the merchants who have physical offline storefronts, they can use XPOS to enable the instant crypto transaction seamlessly. Moreover, as mentioned previously, we are exploring the integration on leading traditional POS terminal so that their distributors have option to enable crypto transaction feature. As for the challenge to adopt XPOS, it is the regulatory compliance in different countries. For this, our legal team think ahead and encourage our merchants to complete KYC.
I must be very honest to say the activation takes longer time than we expect but it will be worth at the end.
* **What’s the average number of transactions per xpos in use?**
Zac: The transaction number has increased very well. The number of each XPOS differs, due to the frequency of using crypto currency to purchase item or crypto assets. There’s no standard answer to this, but overall we see the transaction number and volume are going up.
* **How do you plan to reach the target of 100,000 by 2021?**
Zac: One of the challenges that we have is regulatory compliances in different countries. There are certain markets that do not allow crypto currencies and some require a clear approval for us to deploy XPOS. We are working on both challenges by talking to governments and applying for certifications. So how we plan to reach 100,000 XPOS user by 2021 is to work with distributors, B2B partners on a government / business level, and with existing POS companies to integrate our software solution into the system.
* **We understand as there was bear market and hence Xpos usage demand was low. Are you guys seeing growth of Xpos usage with current market conditions. Can you guys put some statistics comparison like last 30 days Xpos usage vs any month from bear market usage?**
Zac: It is very clear that as we moved out from the bear market, the demand for XPOS has been increasing. As we’ve shared just now both the transaction number and volume of Q2 have beaten Q1. We’ll be able to share more transaction numbers once we receive approval from our XPOS merchants.
One exciting thing is that, with the listing of different tokens, we also see users using these tokens as a way to transact on XPOS, which means we will be having more ways to transact and this is a growth point for XPOS.
* **When will there be more details for XPHONE and XPOS HANDY?**
Zac: For XPOS handy, we have finished production and it will be released in Q3
* **When will the iOS version of XWallet and XPOS be fully translated to other languages?**
Zac: Right now, the XWallet has Traditional Chinese, Korean, Spanish, German and English. With the latest version update, it now includes Portuguese. XPOS also comes with many languages and we hope to finish with more language, either working with professionals or volunteers. If you’re interested in volunteering, please contact us.
* **When will the Merchant back office have Product Registration and SKU id ability and also integrate with other POS software?** * **When will the top-up feature go away for XPOS to allow liquidity for XPOS**
Zac: We constantly update features in XPOS and merchant backend to make it easier for distributors and merchants to use. We understand that one of the ways for mass adoption is to enhance our distributor management system. With that, the distributors can manage manay XPOS at one time with different merchants.
Please stay tuned as we announce more and more functions of this feature. ## On Dubai
* **When will we see the deployment of the XPOS in Dubai?** * **Can we spend NPXS on the Dubai XPOS?**
Zac: As with all big projects there are a lot of moving parts, that includes working very closely with the local government, in Dubai’s case, the Credit Bureau of the Finance Ministry. Things are progressing for the Dubai project but due to confidentiality agreements with the parties involved, we cannot reveal much. All we can say is that we and our Dubai partners are working hard to have XPOS roll-out in the Dubai market and the UAE.
We are also discussing aggressively with Dubai partners whether to include crypto assets in the XPOS in Dubai. That clearly will involve local compliance and legal for that to happen.
* **Your system upgrades expect merchants to have downtime on their XPOS terminals, can you explain if you plan to run a business why this would be considered feasible (specially at the rate you have been doing your upgrades)?**
Zac: Yes, the benefit / strength of the XPOS is that most of the updates can be done on the fly. For example, when we have a token update on our XPOS where developers submit their tokens on Open Platform, the updates of this token are on the fly, which means that once we approve the token on our Open Platform, it will automatically appear on XPOS without any software updates.
The great thing that we believe about XPOS is not just the support of crypto assets, but also the ability to update most things on the fly, which means that whenever we have a good feature or a new token, the updates will be done instantaneously.
* **Can you guys arrange at least a community voting which is the next blockchain we would like to see next in XPOS? Voting will help to prioritize to chose the projects.**
Zac: One of the reasons why BNB is being listed on the XPOS is simply because of its popularity and also our user demand, in a way that we are already answering to our community’s request.
Right now, our main focus is getting all the tokens submitted on Open Platform to be listed on the XPOS. The submission process includes legal and compliance valid, so our legal and compliance teams are working hard to make sure that we have more tokens to roll out onto Open Platform, which means that they will be on XPOS, XWallet, and XPASS.
As to a specific voting mechanism, we’d like to consider that and hopefully we’ll be able to run a specific voting for the chain which users would like to see.
* **While comparing Xpos handy to Square POS devices at least with mobile it’s very cheap like under $30 and easy to use. When can we expect such light weight and cheaper version for XPOS? Is team working on such devices ?**
Zac: There are different POS companies around the globe and pour focus is to work with these POS companies with our software, so that a crypto sales feature will be part of the existing POS system. The more support of crypto asset usage using our software on existing POS, the better it is for global adoption.
We actually strongly believe that the pricing of our POS system is competitive in the market. And one of the great features of the XPOS is that the merchants will not need not to pay a certain percentage to existing acquirer but to be able to earn certain percentage from each transaction. That is the key differentiator for merchant to want to adopt this.
* **From the website with some of the key Countries for XPOS adoption looks great. However, the concern is for Venezuela, there is no reference link like the others have. Can you guys add the link with details to clear the ambiguity?**
Zac: Let’s give a little bit more patience so that we can actually release more information about our Venezuelan partnership. The good news is that we expect concrete news from Venezuela in the coming 2 weeks. So stay up-to-date about our Venezuelan roll out on XPOS, the best way is to subscribe to our telegram group for Venezuela. ## On Partnerships
* **Are there some major partnership in the works? I’m also interested in how you do immediate transactions? Do you anticipate scaling issues?**
Zac: The way XPOS is being designed is that when you use your crypto assets to purchase, it will have instantaneous confirmation because the action is an off-chain process. An on-chain action happens when a user who owns crypto assets in our system transferring the assets out of the Pundi X ecosystem to their own wallets; or to transfer crypto assets in Pundi X from an off-chain to a private wallet, which we will have very soon on XWallet itself.
That is why we are able to handle scaling. When a person wants to use crypto currency to buy a coffee, the transaction will happen instantaneously.
For specific partnership, especially with B2B partnership, we oblige to the NDA that we have signed. But if you follow us closely, you’ll know that we go to different parts of the world, talking to major companies to try to land more deals so that NPXS usage will increase dramatically.
* **Any big partnerships for making xphone or using the software for xBlockchain?**
Zac: These partnerships are also subjected to NDA, so please be patient for us to release more news.
* **When will XPOS have approval to process Visa and MasterCard payments?**
Zac: We have met representatives from these players including some of the key management people. They are obviously looking into crypto currency attentively, and we hope that there’s something we can do with MasterCard and/or Visa.
This is something that the community has suggested and we agree fully. Please allow us with some time to work on this. We have also showcased XPOS to the CEO of MasterCard. For what or when will anything happen, please wait for our official announcement.
* **What’s the status on Quantum fund and their contribution or involvement with Pundi’s project?**
Zac: We announced last year that we are creating a fund to invest in projects beneficial to our ecosystem. We’ve identified some interesting projects, and we have invested in at least 1 project. The reason why we’re investing in that project is because of the services that it will bring onto the Pindi X ecosystem. So the purpose of the investment of the companies is that these companies in turn will benefit on our ecosystem. This is our key consideration.
The team has evaluated the projects that will benefit the Pundi X / Function X ecosystem. Vic and his team will be able to reveal more details on the companies we have invested in and how they will contribute to our ecosystem in Q3.
* **Recent update on NPXSXEM is highly ambiguous as mentioned that it will be now BEP token and later once FX goes live it will get back to Fx platform. Why you guys had so rush to use Binance chain only for few months? Isn’t you guys switching to much in a short time span?**
Zac: Liquidity and utility have been an issue for NPXSXEM. Due to the design philosophy and the limit of token that can be created on NEM’s smart contract, we are only able to create a small number of tokens on NPXSXEM. By moving into the Binance chain for NPXSXEM, the BEP2 token version will be able to support all the NPXSXEM tokens, which means that we’ll migrate and also be able to make sure all the NPXSXEM tokens are under the same contract address.
We believe with the strong liquidity, we will be able to give our NPXSXEM token holders a good reason of what the token holders have been waiting for. We hope to bring NPXSXEM to match the level of NPXS.
* **When #XRP?**
Zac: Our OpenPlatform is a currency agnostic platform, which means that we will work on integrating public chain as well as tokens that are most requested by the users. We’ll also be looking into the listing of different tokens that are being mentioned by the community.
As said, we will have at least one more public chain integration in Q3, perhaps even more.
* **Are you as a company going to try and connect with libra? If they have said they want to be a payment remittance service, have Square, PayPal, Visa on board I as an investor would prefer you try to join them rather than beat such large competitors**
Zac: Of course, we’ll be delighted to work with Facebook and also the Libra coin. Pundi X and XPOS is a currency agnostic / currency neutral platform, if there’s opportunity to list Libra coin or work with Facebook in different ways to promote crypto currency adoption, we’ll certainly look into that and work on reaching out to them. ## On Trading
* **Can you confirm during AMA, Pundi team is not involved with any trading with their own token like selling over time to manage the fund to run the company.**
Zac: All the wallet addresses of the team holdings are disclosed and transparent. This is one of the first things that we did after ICO. Hence, our token holdings are transparent and everyone can monitor our fund transactions. Also, we have strict internal financial regulation and compliance, shows that we are here to build a long-term project.
The best way to make NPXS or the NPXSXEM to rise is real daily life use case.
* **When will you stop manipulating NPXS chart?**
Zac: Our focus has always been and will be building great products. The more product usage, the demands for NPXS and NPXSXEM will increase. Let’s address again that, Pundi X the company is NOT involved in any manipulation of the NPXS price.
There are trading teams, market makers, financial institutions that profit from the drop and rise of token prices in the crypto market. The good thing about NPXS is that we have managed to create a high liquidity by listing on 40+ exchanges and having global trades and demand from all over the world. We hope this and coupled with the fact that we are a solid product and roll out the use cases, the demand of NPXS will only continue to rise and will be able to deter any of the traders or speculators there is for NPXS.
These traders gain profit from manipulating tokens whether BTC or other tokens. In fact, the traditional financial markets have similar challenges as well. What I want to stress is that, we at Pundi X, do NOT speculate or manipulate the price. We work very hard to create demands for NPXS and as a company, it is only beneficial for us to see the prices of NPXS and NPXSXEM rise.
* **Can we please address the elephant in the room which is the Binance bot with huge sell walls and buy walls causing huge distress and concern among users?**
Zac: First, I cannot confirm nor deny that whether Binance has a bot. I think this is something that you need to ask Binance. We need to work with Binance because Binance has one of the biggest liquidities, if not the greatest liquidity, for NPXS. The best way to counter manipulators is to create more use case, more demand and more acceptance of our tokens.
* **Why on almost all exchanges do you not offer a USDT trading pair?**
Zac: We have USDT trading pairs on Bittrex, Bittrue, and more. In addition, we have fiat pairs in Korean Won, IDR, INR, and Turkish liras. We will continue to work on adding trading pairs for NPXS to make it more liquidate.
* **Why don’t you offer a stable coin sell and purchase on the xpos to help with adoption? Places in Africa with volatile currencies would go crazy for this.**
Zac: It’s a great observation. This is a request that’s been asked from many users. We’re working on stable coin listing on XPOS and hopefully it’ll come soon. Stable coin requires a greater compliance and legal validate, which we have been working on since months ago and we hope to have the stable coin up in XPOS soon.
* **When will you add an active tracker for coin burn, whether its measured in usd, NPXS or whatever you choose. The community has been asking for this on twitter, reddit and telegram for this entire year.**
Zac: It will be hard for us to have a daily tracker of the coin burn, but what we might be able to work on is a tracker which have shown all of the tokens that have been removed from the usage. Thank you for giving us this great suggestion and we will work on it in some form.
Zac: Our token supply has always been specified in our white paper, and as promised in our white paper, we will continue to remove tokens through usage and use cases, which we’re working on all the time.
* **Price movement. When will NPXS go to which price?**
Zac: We cannot comment on the change of the price. Our focus is on building products. We hope by doing that the NPXS value will go up. Again, there’s no way that we can comment on the price.
**I believe that burning tokens every 14 weeks keeps the price suppressed and will only lead to huge pumps and dumps. Imo, If the burns were more frequent, the price would move organically.**
Zac: We continue removing tokens quarterly per advised by our legal and compliance team.
**Is it mandatory npxs swap? What happens for token we have in binance?**
Zac: No it’s not a mandatory NPXS swap for FX.
**How many NPXS or NPXSXEM was converted?**
Zac: In Q2, we will remove 29B NPXSXEM and 9B NPXS. ## On XWallet
* **Why not put in XWallet like the place where we can buy and sell like restaurants and shops?**
Zac: You are correct. In fact, if you look at XWallet, there is a merchant feature, whereby you can register as a merchant. By becoming a merchant, you will be able to print out your QR code and stick it on your restaurant. People are able to make payment through this QR code. This will act like a mini-XPOS.
* **In addition to that having multiple different blockchain in XWallet will increase the XWallet adoption. Hence, we would like to see aggressive game plan and execution from the team and would like to hear that**
Zac: That’s a great suggestion. Every day we want to increase use cases for XWallet. In fact, our XWallet update is one of the most frequent in the market. Within 5 months, we have over 10 updates on iOS and Google Play. This does not include soft update which happens every several days. In my view, the effort is very tremendous.
* **Is there any plan to add Swap option within XWallet so that people can trade the coins within XWallet?**
Zac: Yes, there’s such plan and in fact there is an upcoming feature that people will be able to use coins in XWallet to exchange into other things. The exact form and format have not been reviewed. We hope to share more when we have concrete example. But what you suggested is what we are planning for months ago.
* **When will XPOS and XWallet have fiat on ramps?**
Zac: This is a good question. It’s not only involved with regulatory compliance but also involved the technical part. This is also something we are planning for months. Once approved, hopefully we are able to support fiat currency on ramps and off ramps on XWallet.
* **How is the internal organization doing? Currently how many employees work for Pundi? Currently how many job positions are open?**
Zac: Pundi X has grown tremendously. We are now having over seven offices around the globe. I’m sitting in the Singapore office. We have office in Jakarta, Taiwan, Tokyo, Shenzhen, São Paulo and London. These are the places we have physical offices and house approximately 100 full time employees of Pundi X.
The positions open from Pundi X are legal associate in Singapore and other offices. We are looking for more R&D people, especially in Taiwan. We are looking at marketing and PR people in different parts of the world. And we are looking for POS distributors. As a POS distributor, you will work with our business development team and also our technical team to roll out many XPOS which you have a network to control in your local market.
* **Would you consider removing the KYC to allow u.s. holder to stake and be rewarded?**
Zac: We would love to have more users, including US. However, our compliance and legal advisors have not allowed us to accept US holders to stake and be rewarded.
I’m sorry to say that but this is after serious consideration to make such a decision. In fact, it is a very hard decision because we have healthy user base in the US.
will continue to monitor the situation in the different markets and be compliant. There are also ways to be rewarded when using XWallet service without KYC. We are looking into to explore more on this and launch new features. Hopefully we are able to bring the beta version for you to test this week or next. **On XPhone*\
* **Where are we on pre-sale announcement of Xphone? It was highlights of Q2 goal. If we are getting delay, that’s ok. But at least community will have some clarification why it’s getting late and when approximately it coming?**
Zac: Pre-sale order will start this month. It’s likely the end of July. Pre-sale will take place in different channel including the official website and XWallet. Apart of our own channel, the pre-sale will go live on a 3rd party channel. People will be able to pre-order crypto either in crypto or in fiat.
* **Can you discuss in AMA, is participants can pay with Crypto or Credit/debit card or in both ways?**
Zac: As a crypto company, we prefer payment in crypto, but fiat, Visa, MasterCard, and other traditional payment methods will be accepted on different pre-order channels. Stay tuned for pre-order which will happen in late July.
* **Will the Xphone be open to purchase in all regions of the world?**
Zac: Yes, pre-orders will be able to be done on-line, and products will be shipped from our offices to users in different parts of the world.
* **Will the blockchain mode on the Xphone be operable during the testnet or will this function not work until mainnet?**
Zac: XWallet and XPhone are the first channel and avenue for Function X testnet, so once the testnet is operateble, we will start to engage certain services on XWallet and XPhone into Function X testnet, and ultimately into mainnet. Slowly but surely.
* **Does Xphone have hard protective cover,extra Sim slot, also is it enhanced with ip68 water rating?**
Zac: XPhone will not be waterproof, so please do not submerge XPhone into water. XPhone will definitely be eavesdrop-proof because we’re using a blockchain mode, only you and you control your own conversation.
* **Which country accept the Xphone?** * **Will I also be able to use the SIM-card?** * **The blockchain modus will work in every country (what in the absense of nodes)?** * **Will the XPhone I buy now support updates in the future?**
Zac: People from any country will be able to buy XPhone on-line. You will be able to use a SIM for we have built a SIM slot. Wherever you are, the XPhone can be turned on to become a node.
Will XPhone support future updates? Yes, of course. Just like the XPOS, we support silent update. It will be like how we support XPOS, many updates. The updates will always be supported on XPhone. **On Function X*\
* **When is the detail white paper coming for FunctionX? Why the team is very resistive to have well documented white paper? We need scientific approach and well documentation on FunctionX to have developers to be more involved.**
Zac: Yes, developer involvement is a key criterion of the growth of Function X. We have done 2 things, one is that we have set up Function X Foundation which is led by David Ben Kay and will involve third party adviser and board members. Second, we have set up a developer relations team led by one of our own members as well. This team will work on creating developer documents, developer demos and sample, so that excellent developers can tap into working with Function X resources.
The first version of developer documentation is ready in English and Chinese. We are still polishing up the documents and hopefully to release them soon.
We are also working with third party developers, and are engaging at least 2 third party developer companies, so that we can help create their services on Function X and also XWallet.
We are hoping to showcase a smooth and usable service to the audience, we think this is the key criterion of the Function X growth.
Thank you for this suggestion. We need to update more often on github developer documentation as well.
As for the white paper, we did not have one per se because Function X did not do an ICO. But we will continue to update our white paper and include not only technical details, but also details on the chain and how we can get more developers and users so that the future hardware will be added as a node and you will be rewarded financially, at least through our ecosystem genesis fund. Please stay tuned and there are a lot of things going on in the company. Each and one of us is working hard.
* **Why does the FX ecosystem need a decentralized OS?**
Zac: The mantra of Function X is decentralization and having private control of your data. A full private control of your data comes with a decentralized system not just in transmission of your data, but with the operating system built fully for decentralization , which includes a transmission protocol replacing http. The apps uploaded into Function X will be decentralized as well as the data that is stored on the app, which means that how BitCoin or crypto assets are verified on different nodes will also be part of the way we store data and content.
The decentralized OS is key to fulfilling a decentralized environment for a more private and free usage.
* **What about FX are you most excited about?**
Zac: We are actually creating a shift of how people view of blockchain and how decentralization is not just about transacting commercial commodity, but also data, including your identity, are all decentralized. That is what we are most excited about.
The only way for us to achieve this is to have developer support, for we need the developers to build on the foundation we have to offer those exciting services.
* **We understand that developing a new blockchain is time consuming. As a community we are in a dark space to understand where exactly the development of FX right now.**
Zac: We are working hard on creating the testnet and eventually the mainnet. For the latest updates of Function X, what I can encourage you to do is to go on and subscribe to the Function X telegram group where discussions are made. We have formed the Function X Foundation and created the developer relations team, so that the Function X progress will go smoother and with more partnership from outside, whether it’s developers, third party companies, teleco, etc.
* **When FX goes live on the mainnet, will FX coin be used to stake and earn NPXS? how will staking work on that new mainnet?**
Zac: The NPXS/NPXSXEM staking will last till March 9, 2020 as announced. What we are committed is to create more use cases. For FX tokens, the use cases will be focusing on the Function X Chain and the use cases on Function X that include DApp on Function X and different hardware/software services.
* **When fx testnet will be available?**
Zac: First I would like to thank you for your constant support. In Q3, we plan to open Function X testnet so that we will be migrating and creating certain use cases that can be used on Function X testnet, starting with our own XWallet. Which means, the XWallet will migrate some features into Function X testnet, and slowly followed by our other Pundi X products, including XPhones, XPASS, Open Platform and Function X own developer related products from third parties.
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