A Regulatory “Trial and Error” Phase Shaping the Cryptocurrency Ecosystem

In general, the broad aim of regulation is to organise the relationship between persons and to protect their rights and interests in society. However as we have discovered, this has not been the case within the cryptocurrency space.

It has been almost 15 years since Satoshi Nakamoto published the Bitcoin whitepaper. Since then, this seminal document posted on a mailing list, catalysed the emergence of an entirely new-transnational field. Considering the substantial time that has passed and the widespread popularity of cryptocurrencies, one would expect regulators to have at least figured out ‘how’ and ‘what’ to regulate, right? But it appears not so. Regulators do not seem to want to provide long-term, serious solutions, but rather a collection of outdated bandages of reactions that mostly portray the illusion of a solution, with not-so-hidden intentions in mind.

The cryptocurrency ecosystem itself has often been compared to the Wild West. Nevertheless, this also applies to its journey to be regulated. A journey full of ill-suited regulatory approaches that resulted in a plethora of dilemmas. We explore this tension between the technology and regulation in our latest paper “Shaping Cryptocurrency Gatekeepers with a Regulatory ‘Trial and Error’”, with a primary focus on the Financial Action Task Force’s recommendations, and the EU’s 5th Anti-Money Laundering Directive.

Historically speaking, it was only after the rising popularity of the Silk Road and the collapse of the most popular (at the time) exchange Mt. Gox, that regulators realised that they needed to take action. The advertised main objective here is the curbing of criminal activity and providing regulatory protection to consumers/users. However, until only recently, most of the regulatory steps taken by most regulators choosing to act, were approaches mainly targeting money laundering and terrorist financing, with other limited initiatives here and there. Whilst this approach might have had some potential benefits, it was not 1. comprehensive, 2. global, 3. stable/constant, or 4. tailored to address the specific risks and characteristics of cryptocurrencies. In other words, different regulators have been testing diverse approaches, simultaneously, without engaging with one another, and without properly acknowledging the true needs and risks of the ecosystem.

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Rugpull reports in the DeFi jungle

A rising category of cryptocurrency scams called ‘rugpulls’ accounted for 37% of all cryptocurrency scam revenue in 2021. A rugpull is an exit scam in the DeFi (Decentralized Finance) ecosystem where developers abandon a project without fully delivering and run away with investors’ funds. Thodex, a Turkish centralized exchange, ran away with $2 billion from victims. In March 2022, the U.S. Department of Justice charged two defendants for a $1.1 million NFT rugpull scam called Frosties.

In our paper to be presented next week at Financial Cryptography and Data Security 2023, we analyze an updated list of rugpulls from an online discussion forum – bitcointalk.org. This forum provides a platform for everyone to discuss anything on crypto that also attracts scammers to advertise their projects. We observe that since 2020, the number of rugpull threads has increased, while the ones containing exit scams have decreased; the total mention of either of these terms is relatively stable over time. This means that users have started using the term ‘rugpull’ instead of ‘exit scam’ since the DeFi space emerged.

Using keywords to search for threads discussing rugpulls, we found 101 rugpulls from six services, summarised in Table 1. Our dataset is available from the Harvard Dataverse as doi:10.7910/DVN/SMGMW8.

Service Type Definition Observation
Initial Coin Offerings (ICOs) Raising money to create a new ERC20 token 73
Yield farms Lending crypto assets to earn interest on the loan 16
Exchanges Platforms for users to buy/sell cryptocurrency 5
Non-Fungible Tokens (NFTs) Unique, non-interchangeable digital asset that can be bought and sold 5
Initial Dex Offerings (IDOs) Similar to ICO, but on a decentralized exchange 1
Cloud mining Fractional shares of a mining operation 1
Table 1: DeFi service types by quantity of observed rugpulls (N=101)

We find that Initial Coin Offerings (ICOs) form the majority of rugpulls, and most of them pulled the rug in less than six months. For example, the SquidGame Token, named after a famous TV show, rugpulled within days in 2021.

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Return of a new version of Drinik Android malware targeting Indian Taxpayers

In October last year, analysts at Cyble published an article on the return of the Drinik malware that was first spotted by CERT-In in 2016. Last month during the tax-paying season of the year, I (Sharad Agarwal), a Ph.D. student at University College London (UCL) researching SMS phishing, found and identified an updated version of the Drinik malware that impersonates the Income Tax Department of India and targets the victim’s UPI (Unified Payment Interface) payment apps.

The iAssist.apk malware was being spread from the URL hxxp://198[.]46[.]177[.]176/IT-R/?id={mobile number} where the user is deceived into downloading a new version of the app, impersonating the Income Tax Department of India. Along with Daniel Arp, I analyzed the malware sample to check for new functionalities compared to previous versions. In the following, we give a brief overview of our findings.


Our analysis found that the malware communicates with the Command & Control (C&C) server hxxp://msr[.]servehttp[.]com, which is hosted on IP 107[.]174[.]45[.]116. It also silently drops another malicious APK file hosted on the C&C to the victim’s mobile that has already been identified and flagged as malware on VirusTotal – “GAnalytics.apk“.

The previous campaign used a different IP for its C&C communication. However, the hosting provider for the IP addresses, “ColoCrossing“, is the same as in the previous campaign. This strongly indicates that the Threat Actor behind both campaigns is also the same and is abusing the same hosting provider again. As has already been reported for previous versions of this malware, also the most recent version of the malware records the screen of the mobile device and sends the recorded data to the C&C server (see Figure 1).

Function to upload recorded videos to external C&C server.
Figure 1: Function to upload recorded videos to external C&C server.

Additionally, we also found the phone numbers used by the criminals to which the SMSs are sent through this malware (see Table 1). The malicious APK asks for READ, WRITE, RECEIVE, and SEND SMS permission during the installation and does not work unless the user accepts all the permissions (see Table 2).

Indicator Type Indicators
MD5 02e0f25d4a715e970cb235f781c855de
SHA256 99422143d1c7c82af73f8fdfbf5a0ce4ff32f899014241be5616a804d2104ebf
C&C hostname hxxp://msr[.]servehttp[.]com
C&C IP Address 107[.]174[.]45[.]116
Dropped APK URL hxxp://107[.]174[.]45[.]116/a/GAnalytics[.]apk
Dropped APK MD5 95adedcdcb650e476bfc1ad76ba09ca1
Dropped APK SHA256 095fde0070e8c1a10342ab0c1edbed659456947a2d4ee9a412f1cd1ff50eb797
UPI Apps targetted Paytm, Phonepe, and GooglePay
SMS sent to Phone numbers +91-7829-806-961 (Vodafone), +91-7414-984-964 (Airtel, Jaora, Madhya Pradesh), and +91-9686-590-728 (Airtel, Karnataka)
Table 1: Indicators of Compromise (IoCs)

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A well-executed exercise in snake oil evaluation

In the umpteenth chapter of UK governments battling encryption, Priti Patel in September 2021 launched the “Safety Tech Challenge”. It was to give five companies £85K each to develop “innovative technologies to keep children safe when using end-to-end encrypted messaging services”. Tasked with evaluating the outcomes was the REPHRAIN project, the consortium given £7M to address online harms. I had been part of the UKRI 2020 panel awarding this grant, and believed then and now that it concerns a politically laden and technically difficult task, that was handed to a group of eminently sensible scientists.1 While the call had strongly invited teams to promise the impossible in order to placate the political goals, this team (and some other consortia too) wisely declined to do so, and remained realistic.

The evaluation results have now come back, and the REPHRAIN team have done a very decent job given that they had to evaluate five different brands of snake oil with their hands tied behind their backs. In doing so, they have made a valuable contribution to the development of trustworthy AI in the important application area of online (child) safety technology.

The Safety Tech Challenge

The Safety Tech Challenge was always intellectually dishonest. The essence of end-to-end encryption (E2EE) is that nothing2 can be known about encrypted information by anyone other than the sender and receiver. Not whether the last bit is a 0, not whether the message is CSAM (child sexual abuse material).3 The final REPHRAIN report indeed states there is “no published research on computational tools that can prevent CSAM in E2EE”.

In terms of technologies, there really also is no such thing as “in the context of E2EE”: the messages are agnostic as to whether they are about to be encrypted (on the sender side) or have just been decrypted (on the receiving side), and nothing meaningful can be done4 in between; any technologies that can be developed are agnostic of when they get invoked.

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“I am yet to meet a young person that has not experienced some form of abuse via tech”

Technology-facilitated abuse describes the misuse of digital systems such as smartphones or other Internet-connected devices to monitor, control and harm individuals. In recent years increasing attention has been given to this phenomenon in school settings and the criminal justice system. Yet, an awareness in the healthcare sector is lacking. To address this gap, Dr Isabel Straw and Dr Leonie Tanczer from University College London (UCL) have been leading a new research project that examines technology-facilitated abuse in medical settings.

Technology-facilitated forms of abuse are on the rise, with perpetrators adapting digital technologies such as smartphones and drones, trackers such as AirTags, and spyware tools including parental control software, to cause harm. The impact of technology-facilitated abuse on patients may not always be immediately obvious to healthcare professionals. For instance, smart, Internet-connected devices have been showcased to be misused in domestic abuse cases to inflict physical harm. Smart locks have been used to trap individuals inside their homes, smart thermostats have been used to inflict extremes of temperature on victims, and remotely controlled lighting and sound systems have been manipulated to cause psychological distress. COVID-19 catalyzed the proliferation of these technologies within our environment, with sales of smart devices increasing 30% on last year. Yet, while these tools are advertised for their proposed safety and convenience, they are also providing new avenues for violence, harassment, and abuse.

The impact of technology-facilitated abuse is especially notable on young people. In recent years, pediatric safeguarding guidelines have been amended in response to increasing rates of knife crime, gang violence and drug trafficking in the UK. However, technology-facilitated abuse has evolved at a parallel rate and has not received the same level of attention. The impact of technology-facilitated abuse on children and teenagers may manifest as emotional distress, anxiety, suicidal ideation. Koubel reports the exacerbation of mental health risks born from websites that encourage self-harm, eating disorders, and suicide. Furthermore, technology-facilitated dating abuse and sextortion is increasing amongst adolescent populations. With 10% of children being affected by sexual solicitation online, the problem is widespread and under-investigated. As reported by Stonard et al. in “They’ll Always Find a Way to Get to You, digital devices are playing an increasing role in relationship abuse amongst young people.

Vulnerable individuals frequently perceive medical settings as a place of safety. Healthcare professionals, thus, have a role in providing both medical and psychosocial care to ensure their wellbeing. At present, existing clinical and patient management protocols are outdated and do not address the emerging threats of technology-facilitated abuse. For clinicians to provide effective care to patients affected by technological elements of abuse and violence, clinical safeguarding protocols need a radical update if they are to assist professionals navigating high risk scenarios.

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US proposes to protect bank customers from Authorised Push Payment fraud

This week, at the US House Financial Services Committee hearing, Representative Stephen F. Lynch announced a draft of the Protecting Consumers From Payment Scams Act. If enacted, this would expand the existing protection for US customers (Regulation E) who have funds transferred out of their account without their consent, to also cover when the customer is tricked into performing the fraudulent transfer themselves. This development is happening in parallel with efforts in the UK and elsewhere to reduce fraud and better protect victims. However, the draft act’s approach is notably different from the UK approach – it’s simpler, gives stronger protection to customers, and shifts liability to the bank receiving fraudulent transfers. In this post, I’ll discuss these differences and what the implications might be.

The type of fraud the proposed law deals with, where criminals coerce victims into making payment under false pretences, is known as Authorised Push Payment (APP) fraud and is a problem worldwide. In the UK, APP fraud is now by far the most common type of payment fraud, with losses of £355 million in the first half of 2021, more than all types of card fraud put together (£261 million).

APP fraud falls outside of existing consumer protection, so victims are commonly held liable for the losses. The effects can be life-changing, with people losing 6-figure sums within minutes. It’s therefore welcome to see moves to better consumer protection. The UK was one of the first to tackle this problem, with a voluntary code of practice being put in place following years of campaigning by consumer rights organisations, particularly Which.

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Evidence Critical Systems: Designing for Dispute Resolution

On Friday, 39 subpostmasters had their criminal convictions overturned by the Court of Appeal. These individuals ran post office branches and were prosecuted for theft, fraud and false accounting based on evidence from Horizon, the Post Office computer system created by Fujitsu. Horizon’s evidence was asserted to be reliable by the Post Office, who mounted these prosecutions, and was accepted as proof by the courts for decades. It was only through a long and expensive court case that a true record of Horizon’s problems became publicly known, with the judge concluding that it was “not remotely reliable”, and so allowing these successful appeals against conviction.

The 39 quashed convictions are only the tip of the iceberg. More than 900 subpostmasters were prosecuted based on evidence from Horizon, and many more were forced to reimburse the Post Office for losses that might never have existed. It could be the largest miscarriage of justice the UK has ever seen, and at the centre is the Horizon computer system. The causes of this failure are complex, but one of the most critical is that neither the Post Office nor Fujitsu disclosed the information necessary to establish the reliability (or lack thereof) of Horizon to subpostmasters disputing its evidence. Their reasons for not doing so include that it would be expensive to collect the information, that the details of the system are confidential, and disclosing the information would harm their ability to conduct future prosecutions.

The judgment quashing the convictions had harsh words about this failure of disclosure, but this doesn’t get away from the fact that over 900 prosecutions took place before the problem was identified. There could easily have been more. Similar questions have been raised relating to payment disputes: when a customer claims to be the victim of fraud but the bank says it’s the customer’s fault, could a computer failure be the cause? Both the Post Office and banking industry rely on the legal presumption in England and Wales that computers operate correctly. The responsibility for showing otherwise is for the subpostmaster or banking customer.

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Still treating users as the enemy: entrapment and the escalating nastiness of simulated phishing campaigns

Three years ago, we made the case against phishing your own employees through simulated phishing campaigns. They do little to improve security: click rates tend to be reduced (temporarily) but not to zero – and each remaining click can enable an attack. They also have a hidden cost in terms of productivity – employees have to spend time processing more emails that are not relevant to their work, and then spend more time pondering whether to act on emails. In a recent paper, Melanie Volkamer and colleagues provided a detailed listing of the pros and cons from the perspectives of security, human factors and law. One of the legal risks was finding yourself in court with one of the 600-pound digital enterprise gorillas for trademark infringement – Facebook objected to their trademark and domain being impersonated. They also likely don’t want their brand to be used in attacks because, contrary to what some vendors tell you, being tricked by your employer is not a pleasant experience. Negative emotions experienced with an event often transfer to anyone or anything associated with it – and negative emotions are not what you want associated with your brand if your business depends on keeping billions of users engaging with your services as often as possible.

Recent tactics employed by the providers of phishing campaigns can only be described as entrapment – to “demonstrate” the need for their services, they create messages that almost everyone will click on. Employees of the Chicago Tribune and GoDaddy, for instance, received emails promising bonuses. Employees had hope of extra pay raised and then cruelly dashed, and on top, were hectored for being careless about phishing. Some employees vented their rage publicly on Twitter, and the companies involved apologised. The negative publicity may eventually be forgotten, but the resentment of employees feeling not only tricked but humiliated and betrayed, will not fade any time soon. The increasing nastiness of entrapment has seen employees targeted with promises of COVID vaccinations from employers – who then find themselves being ridiculed for their gullibility instead of lauded for their willingness to help.

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Thoughts on the Future Implications of Microsoft’s Legal Approach towards the TrickBot Takedown

Just this week, Microsoft announced its takedown operation against the TrickBot botnet, in collaboration with other cybersecurity partners, such as FS-ISAC, ESET, and Symantec. This takedown followed Microsoft’s successful application for a court order this month, enabling them to enact technical disruption against the botnet. Such legal processes are typical and necessary precursors to such counter-operations.

However, what was of particular interest, in this case, was the legal precedent Microsoft (successfully) sought, which was based on breaches of copyright law. Specifically, they founded their claim on the alleged reuse (and misuse) of Microsoft’s copyrighted software – the Windows 8 SDK – by the TrickBot malware authors.

Now, it is clear that this takedown operation is not likely to cripple the entirety of the TrickBot operation. As numerous researchers have found (e.g., Stone-Gross et al., 2011; Edwards et al., 2015), a takedown operation often works well in the short-term, but the long-term effects are highly variable. More often than not, unless they are arrested, and their infrastructure is seized, botnet operators tend to respond to such counter-operations by redeploying their infrastructure to new servers and ISPs, moving their operations to other geographic regions or new targets, and/or adapting their malware to become more resistant to detection and analysis. In fact, these are just some of the behaviours we observed in a case-by-case longitudinal study on botnets targeted by law enforcement (one of which involved Dyre, a predecessor of the TrickBot malware). A pre-print of this study is soon to be released.

So, no, I’m not proposing to discuss the long-term efficacy of takedown operations such as this. That is for another blog post.

Rather, what I want to discuss (or, perhaps, more accurately, put forward as some initial thoughts) are the potential implications of Microsoft’s legal approach to obtaining the court order (which is incumbent for such operations) on future botnet takedowns, particularly in the area of malicious code reuse.

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Consider unintended harms of cybersecurity controls, as they might harm the people you are trying to protect

Well-meaning cybersecurity risk owners will deploy countermeasures in an effort to manage the risks they see affecting their services or systems. What is not often considered is that those countermeasures may produce unintended, negative consequences themselves. These unintended consequences can potentially be harmful, adversely affecting user behaviour, user inclusion, or the infrastructure itself (including services of others).

Here, I describe a framework co-developed with several international researchers at a Dagstuhl seminar in mid-2019, resulting in an eCrime 2019 paper later in the year. We were drawn together by an interest in understanding unintended harms of cybersecurity countermeasures, and encouraging efforts to preemptively identify and avoid these harms. Our collaboration on this theme drew on our varied and multidisciplinary backgrounds and interests, including not only risk management and cybercrime, but also security usability, systems engineering, and security economics.

We saw it as necessary to focus on situations where there is often an urgency to counter threats, but where efforts to manage threats have the potential to introduce harms. As documented in the recently published seminar report, we explored specific situations in which potential harms may make resolving the overarching problems more difficult, and as such cannot be ignored – especially where potentially harmful countermeasures ought to be avoided. Example case studies of particular importance include tech-abuse by an intimate partner, online disinformation campaigns, combating CEO fraud and phishing emails in organisations, and online dating fraud.

Consider disinformation campaigns, for example. Efforts to counter disinformation on social media platforms can include fact-checking and automated detection algorithms behind the scenes. These can reduce the burden on users to address the problem. However, automation can also reduce users’ scepticism towards the information they see; fact-checking can be appropriated as a tool by any one group to challenge viewpoints of dissimilar groups.

We then see how unintended harms can shift the burden of managing cybersecurity to others in the ecosystem without them necessarily expecting it or being prepared for it. There can be vulnerable populations which are disadvantaged by the effects of a control more than others. An example may be legitimate users of social media who are removed – or have their content removed – from a platform, due to traits shared with malicious actors or behaviour, e.g., referring to some of the same topics, irrespective of sentiment – an example of ‘Misclassification’, in the list below. If a user, user group, or their online activity are removed from the system, the risk owner for that system may not notice that problems have been created for users in this way – they simply will not see them, as their actions have excluded them. Anticipating and avoiding unintended harms is then crucial before any such outcomes can occur.

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