Strong Customer Authentication in the Payment Services Directive 2

Within the European Union, since 2007, banks are regulated by the Payment Services Directive. This directive sets out which types of institutions can offer payment services, and what rules they must follow. Importantly for customers, these rules include in what circumstances a fraud victim is entitled to a refund. In 2015 the European Parliament adopted a substantial revision to the directive, the Payment Services Directive 2 (PSD2), and it will soon be implemented by EU member states. One of the major changes in PSD2 is the requirement for banks to implement Strong Customer Authentication (SCA) for transactions, more commonly known as two-factor authentication – authentication codes based on two or more elements selected from something only the user knows, something only the user possesses, and something the user is. Moreover, the authentication codes must be linked to the recipient and amount of the transaction, which the customer must be made aware of.

The PSD2 does not detail the requirements of Strong Customer Authentication, nor the permitted exemptions to this rule. Instead, these decisions are to be made by the European Banking Authority (EBA) through Regulatory Technical Standards (RTS). As part of the development of these technical standards the EBA opened an initial discussion, to which we submitted a response based on our research on the security usability of banking authentication. Based on the discussion, the EBA produced a consultation paper incorporating a set of draft technical standards. In our response to this consultation paper, included below, we detailed how research both on security usability and banking authentication more broadly should guide the assessment of Strong Customer Authentication. Specifically we point out that there is an incorrect assumption of an inherent tradeoff between security and usability, that for a system to be secure it must be usable, and that evaluation of Strong Customer Authentication systems should be independent, transparent, and follow principles developed from latest research.

False trade-off between security and usability

In the reasoning presented in the consultation paper there is an assumption that a trade-off must be made between security and usability, e.g. paragraph 6 “Finally, the objective of ensuring a high degree of security and safety would suggest that the [European Banking Authority’s] Technical Standards should be onerous in terms of authentication, whereas the objective of user-friendliness would suggest that the [Regulatory Technical Standards] should rather promote the competing aim of customer convenience, such as one-click payments.”

This security/usability trade-off is not inherent to Strong Customer Authentication (SCA), and in fact the opposite is more commonly true: in order for SCA to be secure it must also be usable “because if the security is usable, users will do the security tasks, rather than ignore or circumvent them”. Also, SCA that is usable will make it more likely that customers will detect fraud because they will not have to expend their limited attention on just performing the actions required to make the SCA work. A small subset (10–15%) of participants in some studies reasoned that the fact that a security mechanism required a lot of effort from them meant it was secure. But that is a misconception that must not be used as an excuse for effortful authentication procedures.

Continue reading Strong Customer Authentication in the Payment Services Directive 2

Microsoft Ireland: winning the battle for privacy but losing the war

On Thursday, Microsoft won an important federal appeals court case against the US government. The case centres on a warrant issued in December 2013, requiring Microsoft to disclose emails and other records for a particular email address which was related to a narcotics investigation. It transpired that these emails were stored in a Microsoft datacenter in Ireland, but the US government argued that, since Microsoft is a US company and can easily copy the data into the US, a US warrant would suffice. Microsoft argued that the proper way for the US government to obtain the data is through the Mutual Legal Assistance Treaty (MLAT) between the US and Ireland, where an Irish court would decide, according to Irish law, whether the data should be handed over to US authorities. Part of the US government’s objection to this approach was that the MLAT process is sometimes very slow, although though the Irish government has committed to consider any such request “expeditiously”.

The appeal court decision is an important victory for Microsoft (following two lower courts ruling against them) because they sell their european datacenters as giving their european customers confidence that their data will be subject to the more stringent european privacy laws. Microsoft’s case was understandably supported by other technology companies in the same position, as well as civil liberties organisations such as the Electronic Frontier Foundation in the US and the Open Rights Group in the UK. However, I have mixed opinions about the outcome: while probably the right decision in this case, the wider consequences could be detrimental to privacy.

Both sides of the case wanted to set a precedent (if not legally, at least in practice). The US government wanted US law to apply to data held by US companies, wherever in the world the data resides. Microsoft wanted the location of the data to imply which legal regime applied, and so their customers could be confident that their own country’s laws will be respected, provided Microsoft have a datacenter in their own country (or at least one with compatible laws). My concern is that this ruling will give false assurance to customers of US companies, because in other circumstances a different decision could quite easily be taken.

We know about this case because Microsoft chose to challenge it in court, and were able to do so. This is the first time Microsoft has challenged a US warrant for data stored in their Irish datacenter despite it being in operation for three years prior to the case. Had the email address been associated with a more serious crime, or the demand for emails accompanied by a gagging order, it may not have been challenged. Microsoft and other technology companies may still choose to accept, or may even be forced to accept, the applicability of future US warrants to data they control, regardless of the court decision last week. One extreme approach to compel this approach would be for the US to jail employees until their demands are complied with.

For this reason, I have argued that control over data is more important than where data resides. If a company does not have the technical capability to comply with an order, it is easier for them to defend their case, and so protects both the company’s customers and staff. Microsoft have taken precisely this approach for their new German datacenters, which will be operated by staff in Germany working for a German “data trustee” (Deutsche Telekom). In contrast to their Irish datacenter, Microsoft staff will be unable to access customer data, except with the permission of and oversight from the data trustee.

While the data trustee model resists information being obtained through improper legal means, a malicious employee could still break rules for personal gain, or the systems designed to process legal requests could be hacked into. With modern security techniques it is possible to do better. End-to-end encryption for instant messaging is one such example, because (if designed properly) the communications provider does not have access to messages they carry. A more sophisticated approach is “distributed consensus”, where a decision is only taken if a majority of participants agree. The consensus process is automated and enforced through cryptography, ensuring that rules are respected even if some participants are malicious. Critical decisions in the Tor network and in Bitcoin are taken this way. More generally, there is a growing recognition that purely legal or procedural mechanisms are insufficient to protect privacy. This is one of the common threads present in much of the research presented at the Privacy Enhancing Technologies Symposium, being held this week in Darmstadt: recognising that there will always be imperfections in software, people and procedures and showing that nevertheless individual’s privacy can still be protected.

Cybersecurity: Supporting a Resilient and Trustworthy System for the UK

Yesterday, the Royal Society published their report on cybersecurity policy, practice and research – Progress and Research in Cybersecurity: Supporting a Resilient and Trustworthy System for the UK. The report includes 10 recommendations for government, industry, universities and research funders, covering the topics of trust, resilience, research and translation. This major report was written based on evidence gathered from an open call, as well as meetings with key stakeholders, guided by a steering committee which included UCL members M. Angela Sasse and Steven Murdoch. Here, we summarise what we think are the most important signposts for cybersecurity research and practice.

The report points out that, as online technology and services touches nearly everyone’s lives, the role of cybersecurity is to support a resilient digital economy and society in the UK. Previously, the government focus was very much on national security – but it is just as important that we are able to secure our personal data, financial assets and homes, and that our decisions as consumers and citizens are not manipulated or subverted. The report rightly states that the national authority for cybersecurity needs to be transparent, expert and have a clear and widely-understood remit. The creation of the National Cyber Security Center (NCSC) may be a first step towards this, but the report also points out that currently, it is to be under control of GCHQ – and this is bound to be a problem given the lack of trust they have from parts of industry and civil society, as a result of their role in subverting the development of security standards in order to make surveillance easier.

The report furthermore recommends that the government preserves the robustness of encryption, including end-to-end encryption and promotes its widespread use. Encryption and other computer security measures provides the foundation that allows individuals to trust organisations and attempts to weaken these measures in order to facilitate surveillance will create security risks and reduce robustness. Whether weaknesses are created by requiring fragile encryption algorithms or mandating exceptional access, these attempts increase the risk of unauthorised parties gaining access to sensitive computer systems.

The report also rightly says that companies need to take more responsibility for cyber security: to be a trustworthy business partner or service provider, they need to be competent, and have the correct motivation. “Dumping” the risks associated with online transactions on customers or business partners who don’t have skills and resources to deal with them, and hiding this in complex terms and conditions, is not trustworthy behaviour. Making companies take liability for the security failures will likely play a part in improving trustworthiness, but needs to be done carefully. Important open source software such as OpenSSL is developed by a handful of people in their spare time. When something goes wrong (such as Heartbleed), multi-billion dollar companies who built their business around open source software without contributing or even properly evaluating the risk, should not be able to assign liability to the volunteer developers. Companies should also be transparent and be required to disclose vulnerabilities and breaches. The report calls for such disclosures to be made to a central body, but we would go further and recommend that they be disclosed to the customers exposed to risks as a result of the security failures.

In order to improve and demonstrate competence in cybersecurity, we need evidence-based guidance on state-of-the-art cybersecurity principles, standards and practices. These go further than just following widely used industry practice, or following craft knowledge based on expert opinion, but should be an an ambitious set of criteria which have been demonstrated to make a pronounced improvement in security. A significant effort is required to transform what is currently a set of common practices (the term “best practice” is a misnomer) through empirical tests and measurements into a set of practices and tools that we know to be effective and efficient under real-world conditions (this is the mission of The Research Institute in Science of Cyber Security (RISCS), which has just started a new 5 year phase). The report in particular calls for research on ways to quantify the security offered by anonymization algorithms and anonymous communication techniques, as these perform an critical role in supporting privacy by design.

The report calls for more research, and new means to assess and support research. Cybersecurity is an international field, and research funders should seek for peer-review to be performed by the best expertise available internationally and to remove barriers to international and multidisciplinary research. However, supporting multidisciplinary research should not be at the expense of addressing the many hard technical problems which remain. The report also identifies the benefits of challenge-led funding, where a research programme is led by a world-leading expert with substantial freedom in how research funds are distributed. For this model to work it is critical to create the right environment for recruiting international experts to both lead and participate in such challenges, which as fellow steering-group member Ross Anderson has pointed out, the vote to leave the EU has seriously harmed. Finally, the report calls for improvements to the research commercialisation process, including that universities priorities getting research out into the real world over trying to extract as much money as possible, and that new investment sources are developed to fill in the gaps left by traditional venture capital, such as for software developed for the public good.

Smart contracts beyond the age of innocence

Why have Bitcoin, with its distributed consistent ledger, and now Ethereum with its support for fully fledged “smart contracts,” captured the imagination of so many people, both within and beyond the tech industry? The promise to replace obscure stores of information and arcane contract rules – with their inefficient, ambiguous, and primitive human interpretations – with publicly visible decentralized ledgers reflects the growing technological zeitgeist in their guarantee that all participants would know and be able to foresee the consequences of both their own actions and the actions of all others. The precise specification of contracts as code, with clauses automatically executed depending on certain sets of events and permissible user actions, represents for some a true state of utopia.

Regardless of one’s views on the potential for distributed ledgers, one of the most notable innovations that smart contracts have enabled thus far is the idea of a DAO (Decentralized Autonomous Organization), which is a specific type of investment contract, by which members individually contribute value that then gets collectively invested under some governance model.  In truly transparent fashion, the details of this governance model, including who can vote and how many votes are required for a successful proposal, are all encoded in a smart contract that is published (and thus globally visible) on the distributed ledger.

Today, this vision met a serious stumbling block: a “bug” in the contract of the first majorly successful DAO (which broke records by raising 11 million ether, the equivalent of 150 million USD, in its first two weeks of operation) allowed third parties to start draining its funds, and to eventually make off with 4% of all ether. The immediate response of the Ethereum and DAO community was to suspend activity – seemingly an anathema for a ledger designed to provide high resiliency and availability – and propose two potential solutions: a “soft-fork” that would impose additional rules on miners in order to exclude all future transactions that try to use the stolen ether, or, more drastically (and running directly contrary to the immutability of the ledger),  a “hard-fork” that would roll back the transactions in which the attack took place, in addition to the many legitimate transactions that took place concurrently.  Interestingly, a variant of the bug that enabled the hack was known to and dismissed by the creators of the DAO (and the wider Ethereum community).

While some may be surprised by this series of events, Maurice Wilkes, designer of the EDSAC, one of the first computers, reflected that “[…] the realization came over me with full force that a good part of the remainder of my life was going to be spent in finding errors in my own programs.” It is not the case that because a program is precisely defined it is easy to foresee what it will do once executed on its own under the control of users.  In fact, Rice’s theorem explicitly states that it is not possible in general to show that the result of programs, and thus smart contracts, will have any specific non-trivial property.

This forms the basis on which modern verification techniques operate: they try to define subsets of programs for which it is possible to prove some properties (e.g., through typing), or attempt to prove properties in a post-hoc way (e.g., through verification), but under the understanding that they may fail in general.  There is thus no scientific basis on which one can assert generally that smart contracts can easily provide clarity into and foresight of their consequences.

The unfolding story of the DAO and its consequences for the Ethereum community offers two interesting insights. First, as a sign that the field is maturing, there is an explicit call for understanding the computational space of safe contracts, and contracts with foreseeable consequences. Second, it suggests the need for smart contracts protecting significant assets to include external, possibly social, mechanisms in order to unlock significant value transfers. The willingness of exchanges to suspend trading and of the Ethereum developers to suggest a hard-fork is a last-resort example of such a social mechanism. Thus, politics – the discipline of collective management – reasserts itself as having primacy over human affairs.

Exceptional access provisions in the Investigatory Powers Bill

The Investigatory Powers Bill, being debated in Parliament this week, proposes the first wide-scale update in 15 years to the surveillance powers of the UK law-enforcement and intelligence agencies.

The Bill has several goals: to consolidate some existing surveillance powers currently either scattered throughout other legislation or not even publicly disclosed, to create a wide range of new surveillance powers, and to change the process of authorisation and oversight surrounding the use of surveillance powers. The Bill is complex and, at 245 pages long, makes scrutiny challenging.

The Bill has had its first and second readings in the House of Commons, and has been examined by relevant committees in the Commons. The Bill will now be debated in the ‘report stage’, where MPs will have the chance to propose amendments following committee scrutiny. After this it will progress to a third reading, and then to the House of Lords for further debate, followed by final agreement by both Houses.

So far, four committee reports have been published examining the draft Bill, from the Intelligence and Security Committee of Parliament, the joint House of Lords/House of Commons committee specifically set up to examine the draft Bill, the House of Commons Science and Technology committee (to which I served as technical advisor) and the Joint Committee on Human Rights.

These committees were faced with a difficult task of meeting an accelerated timetable for the Bill, with the government aiming to have it become law by the end of 2016. The reason for the haste is that the Bill would re-instate and extend the ability of the government to compel companies to collect data about their users, even without there being any suspicion of wrongdoing, known as “data retention”. This power was previously set out in the EU Data Retention Directive, but in 2014 the European Court of Justice found it be unlawful.

Emergency legislation passed to temporarily permit the government to continue their activities will expire in December 2016 (but may be repealed earlier if an appeal to the European Court of Justice succeeds).

The four committees which examined the Bill together made 130 recommendations but since the draft was published, the government only slightly changed the Bill, and only a few minor amendments were accepted by the Public Bills committee.

Many questions remain about whether the powers granted by the Bill are justifiable and subject to adequate oversight, but where insights from computer security research are particularly relevant is on the powers to grant law enforcement the ability to bypass normal security mechanisms, sometimes termed “exceptional access”.

Continue reading Exceptional access provisions in the Investigatory Powers Bill

International Comparison of Bank Fraud Reimbursement: Customer Perceptions and Contractual Terms

Terms and Conditions (T&C) are long, convoluted, and are very rarely actually read by customers. Yet when customers are subject to fraud, the content of the T&Cs, along with national regulations, matter. The ability to revoke fraudulent payments and reimburse victims of fraud is one of the main selling points of traditional payment systems, but to be reimbursed a fraud victim may need to demonstrate that they have followed security practices set out in their contract with the bank.

Security advice in banking terms and conditions vary greatly across the world. Our study’s scope included Europe (Cyprus, Denmark, Germany, Greece, Italy, Malta, and the United Kingdom), the United States, Africa (Algeria, Kenya, Nigeria, and South Africa), the Middle East (Bahrain, Egypt, Iraq, Jordan, Kuwait, Lebanon, Oman, Palestine, Qatar, Saudi Arabia, UAE and Yemen), and East Asia (Singapore). Out of 30 banks’ terms and conditions studied, 26 give more or less specific advice on how you may store your PIN. The advice varies from “Never writing the Customer’s password or security details down in a way that someone else could easily understand” (Arab Banking Corp, Algeria), “If the Customer makes a written record of any PIN Code or security procedure, the Customer must make reasonable effort to disguise it and must not keep it with the card for which it is to be used” (National Bank of Kenya) to “any record of the PIN is kept separate from the card and in a safe place” (Nedbank, South Africa).

Half of the T&Cs studied give advice on choosing and changing one’s PIN. Some banks ask customers to immediately choose a new PIN when receiving a PIN from the bank, others don’t include any provision for customers to change their PIN. Some banks give specific advice on how to choose a PIN:

When selecting a substitute ATM-PIN, the Customer shall refrain from selecting any series of consecutive or same or similar numbers or any series of numbers which may easily be ascertainable or identifiable with the Customer…

OCBC, Singapore

Only 5 banks give specific advice about whether you are allowed to re-use your PIN on other payment cards or elsewhere. There is also disagreement about what to do with the PIN advice slip, with 7 banks asking the customer to destroy it.

Some banks also include advice on Internet security. In the UK, HSBC for example demands that customers

always access Internet banking by typing the address into the web browser and use antivirus, antispyware and a personal firewall. If accessing Internet banking from a computer connected to a LAN or a public Internet access device or access point, they must first ensure that nobody else can observe, copy or access their account. They cannot use any software, such as browsers or password managers, to record passwords or other security details, apart from a service provided by the bank. Finally, all security measures recommended by the manufacturer of the device being used to access Internet banking must be followed, such as using a PIN to access a mobile device.


Over half of banks tell customers to use firewalls and anti-virus software. Some even recommend specific commercial software, or tell customers how to find some:

It is also possible to obtain free anti-virus protection. A search for `free anti-virus’ on Google will provide a list of the most popular.

Commercial International Bank, Egypt

In the second part of our paper, we investigate the customers’ perception of banking T&Cs in three countries: Germany, the United States and the United Kingdom. We present the participants with 2 real-life scenarios where individuals are subject to fraud, and ask them to decide on the outcome. We then present the participants with sections of T&Cs representative for their country and ask them then to re-evaluate the outcome of the two scenarios.

Question DE UK US
Scenario 1: Card Loss 41.5% 81.5% 76.8%
Scenario 1: Card Loss after T&Cs 70.7% 66.7% 96.4%
Scenario 2: Phishing 31.7% 37.0% 35.7%
Scenario 2: Phishing after T&Cs 43.9% 46.3% 42.9%

The table above lists the percentage of participants that say that the money should be returned for each of the scenarios. We find that in all but one case, the participants are more likely to have the protagonist reimbursed after reading the terms and conditions. This is noteworthy – our participants are generally reassured by what they read in the T&Cs.

Further, we assess the participants’ comprehension of the T&Cs. Only 35% of participants fully understand the sections, but the regional variations are large: 45% of participants in the US fully understanding the T&Cs but only 22% do so in Germany. This may indeed be related to the differences in consumer protection laws between the countries: In the US, Federal regulations give consumers much stronger protections. In Germany and the UK (and indeed, throughout Europe under the EU’s Payment Service Directive), whether a victim of fraud is reimbursed depends on if he/she has been grossly negligent – a term that is not clearly defined and confused our participants throughout.


International Comparison of Bank Fraud Reimbursement: Customer Perceptions and Contractual Terms by Ingolf Becker, Alice Hutchings, Ruba Abu-Salma, Ross Anderson, Nicholas Bohm, Steven J. Murdoch, M. Angela Sasse and Gianluca Stringhini will be presented at the Workshop on the Economics of Information Security (WEIS), Berkeley, CA USA, 13–14 June 2016.

Are Payment Card Contracts Unfair?

While US bank customers are almost completely protected against fraudulent transactions, in Europe banks are entitled to refuse to reimburse victims of fraud under certain circumstances. The EU Payment Services Directive (PSD) is supposed to protect customers but if the bank can show that the customer has been “grossly negligent” in following the terms and conditions associated with their account then the PSD permits the bank to pass the cost of any fraud on to the customer. The bank doesn’t have to show how the fraud happened, just that the most likely explanation for the fraud is that the customer failed to follow one of the rules set out by the bank on how to protect the account. To be certain of obtaining a refund, a customer must be able to show that he or she complied with every security-related clause of the terms and conditions, or show that the fraud was a result of a flaw in the bank’s security.

The bank terms and conditions, and how customers comply with them, are therefore of critical importance for consumer protection. We set out to answer the question: are these terms and conditions fair, taking into account how customers use their banking facilities? We focussed on ATM payments and in particular how customers manage PINs because ATM fraud losses are paid for by the banks and not retailers, so there is more incentive for the bank to pass losses on to the customer. In our paper – “Are Payment Card Contracts Unfair?” – published at Financial Cryptography 2016 we show that customers have too many PINs to remember them unaided and therefore it is unrealistic to expect customers to comply with all the rules banks set: to choose unguessable PINs, not write them down, and not use them elsewhere (even with different banks). We find that, as a result of these unrealistic expectations, customers do indeed make use of coping mechanisms which reduce security and violate terms and conditions, which puts them in a weak position should they be the victim of fraud.

We surveyed 241 UK bank customers and found that 19% of customers have four or more PINs and 48% of PINs are used at most once a month. As a result of interference (one memory being confused with another) and forgetting over time (if a memory is not exercised frequently it will be lost) it is infeasible for typical customers to remember all their bank PINs unaided. It is therefore inevitable that customers forget PINs (a quarter of our participants had forgot a 4-digit PIN at least once) and take steps to help them recall PINs. Of our participants, 33% recorded their PIN (most commonly in a mobile phone, notebook or diary) and 23% re-used their PIN elsewhere (most commonly to unlock their mobile phone). Both of these coping mechanisms would leave customers at risk of being found liable for fraud.

Customers also use the same PIN on several cards to reduce the burden of remembering PINs – 16% of our participants stated they used this technique, with the same PIN being used on up to 9 cards. Because each card allows the criminal 6 guesses at a PIN (3 on the card itself, and 3 at an ATM) this gives criminals an excellent opportunity to guess PINs and again leave the customer responsible for the losses. Such attacks are made easier by the fact that customers can change their PIN to one which is easier to remember, but also probably easier for criminals to guess (13% of our participants used a mnemonic, most commonly deriving the PIN from a specific date). Bonneau et al. studied in more detail exactly how bank customers select PINs.

Finally we found that PINs are regularly shared with other people, most commonly with a spouse or partner (32% of our participants). Again this violates bank terms and conditions and so puts customers at risk of being held liable for fraud.

Holding customers liable for not being able to follow unrealistic, vague and contradictory advice is grossly unfair to fraud victims. The Payment Services Directive is being revised, and in our submission to the consultation by the European Banking Authority we ask that banks only be permitted to pass fraud losses on to customers if they use authentication mechanisms which are feasible to use without undue effort, given the context of how people actually use banking facilities in normal life. Alternatively, regulators could adopt the tried and tested US model of strong consumer protection, and allow banks to manage risks through fraud detection. The increased trust from this approach might increase transaction volumes and profit for the industry overall.


“Are Payment Card Contracts Unfair?” by Steven J. Murdoch, Ingolf Becker, Ruba Abu-Salma, Ross Anderson, Nicholas Bohm, Alice Hutchings, M. Angela Sasse, and Gianluca Stringhini will be presented at Financial Cryptography and Data Security, Barbados, 22–26 February 2016.

Our contributions to the UK Distributed Ledger Technology report

The UK Government Office for Science, has published its report on “Distributed ledger technology: beyond block chain” to which UCL’s Sarah Meiklejohn, Angela Sasse and myself (George Danezis) contributed parts of the security and privacy material. The review, looks largely at economic, innovation and social aspects of these technologies. Our part discusses potential threats to ledgers, as well as opportunities to build robust security systems using ledgers (Certificate Transparency & CONIKS), and overcome privacy challenges, including a mention of the technology.

You can listen to the podcast interview Sarah gave on the report’s use cases, recommendations, but also more broadly future research directions for distributed ledgers, such as better privacy protection.

In terms of recommendation, I personally welcome the call for the Government Digital Services, and other innovation bodies to building capacity around distributed ledger technologies. The call for more research for efficient and secure ledgers (and the specific mention of cryptography research) is also a good idea, and an obvious need. When it comes to the specific security and privacy recommendation, it simply calls for standards to be established and followed. Sadly this is mildly vague: a standards based approach to designing secure and privacy-friendly systems has not led to major successes. Instead openness in the design, a clear focus on key end-to-end security properties, and the involvement of a wide community of experts might be more productive (and less susceptible to subversion).

The report is well timed: our paper on “Centrally Banked Crypto-Currencies” will be presented in February at a leading security conference, NDSS 2016, by Sarah Meiklejohn, largely inspired by the research agenda published by the Bank of England. It provides some answers to the problems of scalability and eco-friendliness of current proof-of-work based ledger design.