Thread by @RTaylor05

1/ Thread... Here is my take on the announced delisting of Dash on Bittrex.

https://twitter.com/BittrexExchange/status/1345056010981892096

2/ Though not explicitly stated in Bittrex’s announcement, it seems likely that Bittrex undertook this action to mitigate perceived regulatory risk of cryptocurrencies that U.S. government agencies have labeled as Anonymity Enhanced Cryptocurrencies (AECs).

3/ DCG’s and our legal counsel’s perspective is that 1) the recent statements from DOJ and FinCEN do not appear to indicate an intent to demand delisting of AECs, and that 2) Dash is clearly not an AEC to begin with!

4/ We were already working with counsel on responses to both the DOJ’s Crypto Enforcement Framework and FinCEN’s PRM to provide evidence that Dash is not an AEC. We will be submitting a formal written comment to FinCEN’s PRM on Monday. Actively working out a time to meet DOJ.

5/ Firstly, FinCEN’s comments regarding the use of AECs are clearly contextual and listed alongside a list of general advancements in privacy-enhancing technology that could present new challenges to law enforcement.

6/ For example, included in that section are many non-AEC developments such as off-chain transitions (e.g., BTC’s Lightning) and the portability of open-source AEC technologies to existing non-AEC blockchains (e.g., Litecoin’s adoption of mimblewimble).

7/ It is within this overall context that FinCEN is proposing that centralized exchanges collect additional data on transactions. Nowhere does FinCEN state that AECs or off-chain transactions cannot be supported.

8/ In other words, they seem to be saying “there is an overall trend in the cryptocurrency markets toward greater user privacy. In light of that trend, we believe exchanges should be collecting additional data on off-exchange crypto transactions.”

9/ Secondly, Dash is not an AEC! As a literal fork of Bitcoin, all Dash transactions are completely transparent. All inputs, outputs, addresses, and amounts are recorded on each and every transaction and viewable - by anyone - on its public blockchain.

10/ Dash’s PrivateSend feature is simply a branded implementation of non-custodial CoinJoin. Don’t take my word for it… industry leading experts like Chainalysis and Perkins Coie agree.

11/ Chainalysis stated in their announced coverage for Dash, “It’s possible to perform mixing transactions that are functionally identical to PrivateSend on other technologically similar cryptocurrencies. This means from a technical standpoint, Dash’s privacy functionality...

12/ ...is no greater than Bitcoin’s, making the label of “privacy coin” a misnomer for Dash. In fact, independent wallet softwares provide more advanced forms of CoinJoin [e.g., Chaumian CoinJoin] that are being used with major cryptocurrencies not labeled as privacy coins...

13/ ...such as Bitcoin, Bitcoin Cash, and Litecoin.” Source: blog.chainalysis.com/reports/introd…

14/ Perkins Coie stated “since CoinJoin can be used in connection with Bitcoin transactions just as readily as Dash allows, Dash is technically no more of a “privacy coin” than Bitcoin… the widespread perception that Dash is “privacy-centric”... does not accurately reflect...

15/ ...its actual functionality.” Source: perkinscoie.com/images/content…

16/ We’ve even performed “PrivateSend” transactions on Bitcoin’s blockchain to prove that we haven’t altered Bitcoin’s transaction protocol. Here is a “PrivateSend” on the Bitcoin network:
btc.cryptoid.info/btc/tx.dws?2e9…

And on the Dash network:
chainz.cryptoid.info/dash/tx.dws?a8…

17/ Dash has been delisted from several smaller exchanges in the past, and after their compliance teams are educated on the facts, exchanges will usually reverse their decision and relist.

18/ We will of course attempt to work with Bittrex to enable them to relist, assuming they are willing to work with us.

19/ The largest exchanges tend to have in-house counsel with a strong understanding of the technology, and those are far less likely to have a knee-jerk reaction to contextual statements that are used to support a proposed rule-change.

20/ In short, this is not in the same league as the SEC enforcement action taken against Ripple. Not even close. AECs are not - as far as we can tell - targeted from prohibition by U.S. regulators.

21/ Even if they are, Dash is absolutely NOT an AEC and rightfully should be excluded from any such action.

22/ We will continue working to educate FinCEN and DOJ to ensure that they are properly educated on the topic and understand that exchanges are capable of meeting their regulatory obligations while continuing to list Dash.

23/ We faced similar challenges in the past with the SEC. Back in 2018, we faced delistings because the SEC believed Dash may be a security. We put that concern away later that same year. cryptoratingcouncil.com/asset-ratings We will address this perception issue, too.

24/ Just this week, we released Dash Platform to testnet, making Dash capable of hosting its own applications. DashPay wallets with blockchain-based usernames are coming next week. By the end of January, a bunch of really cool announcements are coming that I can’t wait to share.

25/ Dash just had its 9th consecutive quarter of economic transaction growth & hit another record. In fact, growth accelerated to double-digit QonQ. 2021 won’t be bump-free, and I don’t particularly like starting off 2021 with some bad news, but this is merely a bump in the road.