In reply to the Malta Financial Services Authority's (MFSA) warning issued today, the 31st of July, 2017, Bitmalta would like to point out that such a warning would have been justified five years ago in view of the yet-uncertain nature and effect of cryptocurrencies, but not in this day and age when jurisdictions worldwide are readying themselves for acceptance of cryptocurrencies rather than shying away from this technological revolution.
We are extremely disappointed, to say the least, that whereas Malta's Prime Minister Dr. Joseph Muscat and Hon. Silvio Schembri, the Parliamentary Secretary for Financial Services, Digital Economy and Innovation, are actively advocating the adoption of blockchain technologies and cryptocurrencies in Malta, the MFSA are unfortunately still quoting long-since settled risks pertinent to cryptocurrencies and adopting an approach which may be defined as being too cautious. The blockchain technology is firmly rooting itself as "the next big thing", a disruption which will echo that of the Internet back in the late 90s, and cryptocurrencies are but one single application of such a technology, albeit an important one as they show what can be achieved through the use of blockchain technologies. It is therefore of utmost importance to create incubators for such thriving projects to grow unmolested and study them closely, and unfortunately the approach adopted by the MFSA is anything but proactive. Cryptocurrencies are here to stay, whether you ban them or not, so it is advisable, even obvious, that measures should be taken to educate the public about them rather than scaremonger.
The risks cited by the MFSA have been sufficiently covered over the past few years as follows:
Money may be lost on the exchange platform
It is a well-known practice among cryptocurrency holders that funds are best stored on a local PC rather than on an exchange. One of the primary breakthroughs brought about by cryptocurrencies is that they remove the need for any middlemen in transactions, and exchanges should only serve as a temporary means of storage for active trades. Money may also be lost on any other website on which you store e-money too, so that point is moot.
Money may be stolen from your digital wallet
Facebook accounts can also be hacked, and your very identity may be stolen, and anything else connected to the Internet is prone to external attacks. Your data is only as secure as you want it to be, and cryptocurrencies are simply another form of data which is stored onto your computer. If you store your cryptocurrencies on a PC with no security measures in place and no password, for example, then you will be subject to third party attacks. This is another key area in which education would be a godsend, not just for cryptocurrencies but for cyber-security in general. Besides, safe storage solutions such as hardware wallets greatly minimise the risk of any external attacks, as well as multi-signature wallets and additional authentication measures such as Two-Factor Authentication (2FA).
You are not protected when using virtual currencies as a means of payment
Unfortunately neither are you protected when making payment in cash. It all depends on the parties involved in the transaction and the payment channels used. If one were to buy an item using cryptocurrencies from a reputable website with integrated consumer protection, then the applicable risk is the same as if you were to use any other means of payment. If you buy an item from an unknown third party off the dark web, then chances are that whatever means of payment you use, the risks are significantly higher. One should remember that mechanisms such as chargebacks are hotly contested by merchants as a prime avenue for fraud, so there are two sides to the cited argument in the warning.
The value of virtual currency can change quickly, and can even drop to zero
While this statement is partially true, it is likewise possible that the value of the Euro for example due to hyperinflation and unsustainable bailouts. The value of cryptocurrencies is mostly determined through demand and supply, with some cryptocurrencies pegging their value to that of other currencies or commodities, such as Tether which pegs its value to that of the U.S. Dollar (USD). Well-established cryptocurrencies such as Bitcoin have been experienced less volatility as their adoption rate increases, and therefore it is evident that both are correlated and it is simply a matter of time before the issue of volatility diminishes.
Transactions in virtual currencies may be used for criminal activities
The same applies to an even greater extent to transactions in fiat currencies. Suffice it to say that cryptocurrencies rank very low indeed when it comes to use by terrorists. Most cryptocurrencies utilise a public ledger system through which transactions can be tracked, making them a poor choice for money launderers as each and every transaction can be traced once the addresses of the senders/receivers become known. If anything, blockchain technologies allow for a paradigm shift in AML measures as they allow for a much more transparent system than the traditional ones which, safe to say, have been a failure acknowledged by many.
We hope that regulatory authorities such as the MFSA recognise the value and benefits of blockchain technologies as a whole, and that a proactive approach initiated through education is taken so as to enable Malta to become a blockchain hub in practice and not just through words. Bitmalta is readily available for any support in this area, and we would be more than happy to meet with the MFSA in order to address any of their questions and concerns on the subject and furthermore to understand why the MFSA sees a need to (re-)issue such a statement at this particular point in time and how this approach will fit in with the national Blockchain strategy that the Government is working upon. We welcome all cooperation on the matter and advise for a unified approach on the topic.