That is an opinion editorial by Morgan Rockwell, founding father of Bitcoin Kinetics.
I am not involved with Sam Bankman-Fried allegedly getting a mortgage from Alameda, which was truly FTX buyer funds wired by Alameda to be credited on FTX. I am not involved with the ethical compass of the superstar buyers who gave billions to a child they did not actually know or perceive, but endorsed with wealth and credibility. I am not very involved with the monetary and market results upon the numerous firms, exchanges and merchants who for some motive relied on FTX in any kind.
I am most involved with Sam Bankman-Fried getting the non-public identification info of tens of millions of shoppers, and utilizing that knowledge to do chain evaluation on the Blockfolio app he bought which was utilized by many Bitcoiners and cryptocurrency holders as a monitoring device of Bitcoin, Ethereum and different watch-only cryptocurrency wallets.


Supply: Google Pictures
When you aren’t conscious, Blockfolio was an app that was utilized by many Bitcoin holders and different cryptocurrency holders to maintain monitor of the trade fee or the costs of their cash held in chilly storage or on wallets that they solely needed to be watching and never have actively on a sizzling pockets on their cell system. Storing the pockets addresses truly weren’t even wanted on the app. You would simply put in a quantity of a sure cryptocurrency that you just needed to observe and say that you just had — however there was additionally a characteristic to connect with exchanges to maintain monitor of your entire cash throughout the entire exchanges you had them on in a single app. This was the fantastic thing about Blockfolio because it did not essentially ask for an excessive amount of private identification info apart from an e mail to assist preserve monitor of your account so you’ll be able to log in from a number of units.
Most of us like myself turned conscious of Sam Bankman-Fried as a result of of the acquisition of Blockfolio by a newly fashioned entity referred to as FTX. Over a number of weeks the Blockfolio app was rebranded because the FTX app which now had its personal trade. It additionally had a brand new set of Know Your Buyer guidelines, Anti-Cash Laundering insurance policies, a brand new Phrases of Service, in addition to its personal custodial pockets held by FTX, we assumed.
Right here you’ll be able to see the Phrases of Service at Blockfolio from June 30, 2017:
Supply: Blockfolio Privateness Coverage 2017
Blockfolio avidly argued that they weren’t and wouldn’t ever promote person knowledge. Blockfolio even tried to de-identify customers with a hashing mechanism for IDs to not even let themselves determine and join person portfolios to e mail addresses; this apparently by no means occurred after the acquisition and transformation into FTX.
Right here you’ll be able to see the stark distinction within the new FTX Privateness Coverage:
Supply: FTX Privateness Coverage 2022
Here’s what little is talked about about private identifiable info throughout the FTX Phrases of Service, which is a unique doc than the Privateness Coverage.

Supply: FTX Phrases Of Service 2022
For reference, you probably have by no means learn a Phrases Of Service or Privateness Coverage of an organization earlier than, I strongly advocate you seize a robust beer and revel in this phrase soup!
This all has introduced up questions round this merger and the acquisition that occurred within the cryptocurrency trade only some years in the past. I’m involved as a result of after the fallout of this trade, FTX going bankrupt and all of its belongings doubtlessly being put up for public sale, I want to know the state of the non-public identification info that FTX had been pressured to collect due to KYC and AML legal guidelines. My concern is the huge quantity of knowledge gathered together with passports, cellphone numbers, IP addresses, house addresses, cryptocurrency pockets addresses, e mail addresses, passwords and authorities IDs. All of those may very well be offered at public sale as buyer knowledge or buyer profiles to whoever finds them helpful.

Supply: FTX Privateness Coverage (disclosure within the occasion of merger, sale, or different asset transfers)
Now the belongings held by FTX whether or not they had been truly actual cryptocurrency corresponding to bitcoin or made up tokens constructed on one other layer one community corresponding to ethereum will not be too necessary on this dialog for my part. What’s necessary is the information, the privateness knowledge, the information mining operation that might have or shall be executed on all of this knowledge FTX had gathered on clients both it was executed by them or will probably be executed by whomever buys this knowledge at public sale. Much more so, the jurisdiction of that knowledge is open to wherever on earth.
As somebody who has personally labored on coin evaluation ideas and know-how for the USA Navy, in addition to consulted on this for the Division of Protection as a so referred to as “material professional,” I can personally attest that it is vitally straightforward to correlate an individual to their Bitcoin pockets handle utilizing nothing greater than the quantities of bitcoin held on particular addresses, in addition to the system knowledge that’s retaining monitor of these particular quantities on particular addresses — that is easy SIGINT, MASINT or HUMINT, all of that are totally different types of intelligence gathering.

Supply: Wikipedia Search For HUMINT
If you’re retaining monitor of any bitcoin on any pockets over any Bitcoin explorer that’s regarded by a browser or app on any system, cellphone, laptop computer or pill, there may be now a document that shall be linked to the IP handle, the MAC quantity, the SIM cellphone quantity, the VOIP quantity, bank card quantity, house handle and some other private figuring out info that’s hooked up in any solution to this system. I do know this as a result of Edward Snowden leaked paperwork exhibiting that the NSA had a program referred to as XKEYSCORE and purposes had been used like OAKSTAR and its subprogram MONKEYROCKET to particularly preserve monitor of Bitcoin customers on the NSA.

Supply: https://theintercept.com/2018/03/20/the-nsa-worked-to-track-down-bitcoin-users-snowden-documents-reveal/
Now what I am getting at is that this knowledge that FTX was pressured beneath AML and KYC regulation to be gathered. That is doubtlessly one of many largest gatherings of this sort of knowledge within the cryptocurrency trade ever executed in historical past. This knowledge, mixed with coin evaluation info associated to bitcoin, ethereum and different cryptocurrency quantities being tracked by the beforehand titled Blockfolio app has created a scenario the place KYC knowledge private figuring out info will be now superimposed over Blockfolio e mail addresses, UTXOs and watch addresses that loads of individuals used on Blockfolio with none private info being divulged to the app.
So which means that those that used Blockfolio to maintain monitor of the quantity of cryptocurrency that they had, needed to purchase or had been retaining monitor of for no matter motive will now be capable to be correlated to very detailed private identification info. The priority I’ve is just not whether or not FTX and its a whole lot of subsidiaries had been retaining monitor of this info from Blockfolio or utilizing it in any approach, however that their huge new pool of buyer info and knowledge shall be binded sooner or later to the Blockfolio knowledge. I do not assume FTX was clever sufficient to do that for any objective corresponding to promoting, or knowledge sharing with a hedge fund like Robinhood was caught doing, however I do assume that they could have thought of promoting this knowledge to regulation enforcement companies, to advertisers or to actors within the intelligence neighborhood as SBF stated there was an open door to regulators and regulation enforcement companies at FTX.
What we’d like to consider now could be when the belongings of FTX go up for public sale, which they may, that not solely the digital currencies and tokens in addition to the licenses shall be offered to some new get together, however will probably be the shoppers themselves, private figuring out info and the large knowledge mining that might have been or shall be executed with that knowledge.
I used to be by no means an FTX person, I by no means created an account with FTX or FTX.us and I by no means wired any cash to Alameda. Sadly, due to my longevity within the Bitcoin house, I used Blockfolio like many Bitcoin customers earlier than me to maintain monitor of the quantities of Bitcoin I had in a number of areas and their whole worth. Now that knowledge that I assumed was non-public shall be linked to KYC knowledge of anybody I do know, interacted with over a wire and any system they used, particularly if by a number of connections it leads again to FTX in any approach.
What we have to do now could be ask the intense questions and never deal with the monetary obligations or mishandlings of SBF and FTX. However we should ask who has this knowledge? What has been executed with this knowledge and who shall be proudly owning this knowledge sooner or later? The fact is FTT dissolving into nothing is not a “Power Majeure Occasion,” so many of the customers are screwed.
If this in any respect considerations you or includes you, I might counsel all of us discover the correct channels to guard ourselves from the worst case situation from this fallout of knowledge. That is the largest drawback with KYC and AML legal guidelines,as a result of in spite of everything of this monetary chaos, there may be now a criminal-run trade that’s in possession of tens of millions of individuals’s private details about their units, their houses, their financials and extra, all out there to the very best bidder.
Notes:

The Blockfolio TOS & Privateness Coverage go to useless hyperlinks on the FTX.com web site, however I discovered a 2017 model.

You have to check in by Zendesk to view the lacking Blockfolio TOS/PP in addition to the brand new FTX TOS/PP which suggests I needed to give an e mail and PPI to even see the paperwork.
This can be a visitor put up by Morgan Rockwell. Opinions expressed are solely their very own and don’t essentially replicate these of BTC Inc or Bitcoin Journal.