Stablecoins, a new type of financial institution, are unique in two ways. First, they use decentralized databases like Ethereum and Tron to run their platforms. Secondly, and more important for the purposes of this article, they grant access to almost anyone, no questions asked.  I'm going to illustrate this openness by showing how Garantex, a sanctioned Russian exchange that laundered ransomware and darknet payments, has enjoyed almost continual access to financial services offered by stablecoin platforms like Tether and USDC throughout its six year existence, despite a well-known reputation as a bad actor.  Last month, law enforcement seizures combined with an indictment and arrest of Garantex's operators appear to have finally severed Garantex's stablecoin connection... or not. Evidence shows that Garantex simply rebranded and slipped right back onto stablecoin platforms.   Stablecoins' no-vetting model is a stark departure from the finance industry's default due diligence model, adhered to by banks (such as Wells Fargo) and fintechs (such as PayPal). We all know the drill—provide two pieces of ID to open a payments account. Requirements for businesses will probably be more onerous. Anyone on a sanctions list will be left at the door. Banks and fintechs must identify who they let on their platforms because the law requires it. By contrast, to access the Tether or USDC platforms, the two leading U.S. dollar stablecoins, no ID is required. Anyone can start using stablecoin payments services without having to pass through a due diligence process. Sanctioned customers won't get kicked off, as Garantex's long-uninterrupted access shows. Regulators seem to tolerate this arrangement—so far, no stablecoin operators have faced penalties for money laundering or sanctions evasion. A quick history of the Tether-Garantex nexus Garantex became notorious early on for its role in laundering ransomware payments. Russian ransomware gangs hacked Western firms, extorted them for bitcoin ransoms, and cashed out at Moscow-based exchanges like Garantex. Garantex also became a popular venue for laundering darknet-related proceeds, particularly Hydra, once the largest darknet market. Reports allege that the exchange's shareholders have Kremlin links and that terror groups Hezbollah and Quds Force have used it. Founded in 2019, Garantex was connected to Tether's platform by August 2020. We know this because an archived version of Garantex's website from that month show trading and payment services being offered using Tether's token, USDT. Archived Garantex.org trading page from March 2024 with USDT-to-ruble, Dai-ruble, and USDC-ruble markets [link] This connection to Tether allowed Garantex's customers to transfer their Tether balances to Garantex's Tether wallet, in the same way that a shopper might use their U.S. dollar account at PayPal to make payments to a business with a PayPal account. This allowed Garantex's users to trade U.S. dollars (in the form of Tether) on its platform for bitcoins or ether, two volatile cryptocurrencies, and vice versa. The Tether linkage also meant that Garantex could offer a market for trading ruble-USD. By April 2022, Garantex's bad behaviour had caught up to it: the exchange was sanctioned by the U.S. Treasury's Office of Foreign Asset Control (OFAC). U.S. individual and entities were now prohibited from doing business with Garantex. Out of fear of being penalized, most non-Russian financial institutions would have quickly severed ties with it. Yet Tether, based in the British Virgin Islands at the time, permitted its relationship with Garantex to continue without interruption. Archived copies of Garantex's trading page from mid-2022 and 2023 show that Tether-denominated services were still being offered. The Wall Street Journal reported in 2023 that around 80% of the exchange’s trading involved Tether, despite sanctions being in place. The net amounts were not small. According to Bloomberg, an alleged $20 billion worth of Tether had been transacted via Garantex post-sanctions. A 2024 Wall Street Journal report revealed that sanctions-evading middlemen used Tether to "break up the connection" between buyers like Kalashnikov and sellers in Hong Kong, with Garantex serving as their venue for acquiring Tether balances.  Finally, analysis from Elliptic, a blockchain analytics firm, alleges that Garantex offered USDT trading services to North Korean hacking group Lazarus in June 2023. This transaction flow is illustrated below: The Garantex/Tether nexus in 2023: Elliptic alleges that North Korean hackers stole ether from Atomic Wallet, converted it to Tether using a decentralized exchange 1inch, and then sent Tether to Garantex to trade for bitcoin. (Click to enlarge.) Source: Twitter, Elliptic Tether's excuse for not off-boarding sanctioned entities such as Garantex? A supposed lack of government clarity.  When Tornado Cash was sanctioned in 2022, for instance, the company said that it would "hold firm" and not comply because the U.S. Treasury had "not indicated" whether stablecoin issuers were required to ban sanctioned entities from using what Tether refers to as "secondary market addresses." Translating, Tether was saying that if bad actors wanted to use Tether's platform to transact with other Tether users (i.e. in the "secondary market"), it would let them do so. Tether's only obligation, the company believed, was to stop sanctioned users from asking Tether itself to directly cash them out of the platform into U.S. dollars (i.e. the "primary market"). This is quite the statement. Imagine if PayPal allowed everyone—including sanctioned actors—to open an account without ID and send funds freely within its system, only intervening when bad actors asked PayPal to cash them out into regular dollars. That was Tether's stance. Or if Wells Fargo let sanctioned actors make payments with other Wells Fargo customers, but only stopped them from withdrawing at ATM. Banks and fintechs can't get away with such a bare bones compliance strategy; they must do due diligence on all their users. But Tether seemed to believe that a different set of rules applied to it. In December 2023, Tether reversed course. It would now initiate a new "voluntary" policy of freezing out all OFAC-listed actors using its platform, not just "primary market" sanctioned users seeking direct cash-outs. This brought Tether into what it described as "alignment" with the U.S. Treasury. Soon after, Tether froze three wallets linked by OFAC in 2022 to Garantex. However, this action was largely symbolic. By the time Tether froze those wallets, Garantex had already abandoned them and opened new ones, thus allowing the exchange to maintain access to Tether's platform. Tether's no-vetting model permitted this pivot. Archived versions of Garantex's trading page show that it continued offering Tether services throughout 2024 and early 2025. The U.S. Department of Justice recently confirmed Garantex's tactic of replacing wallets in its March 2025 indictment of the exchange's operators. It alleges that Garantex frequently cycled through new Tether wallet addresses—sometimes on a daily basis—to evade detection by U.S.-based crypto exchanges like Coinbase and Kraken, which are legally required to block customer payments made to sanctioned entities. That the relationship between Tether and Garantex continued even after Tether's supposed 180 degree turn to "align" itself with the U.S. government is backed up by several reports from blockchain analytics firm Chainalysis. The first, published in August 2024, found that a large purchaser of Russian drones used Garantex to process more than $100 million in Tether transactions. The second describes how Russian disinformation campaigners received $200,000 worth of Tether balances in 2023 and 2024, much of it directly from Garantex. In a March 2024 podcast, Chainalysis executives allege that "a majority" of activity on Garantex continued to be in stablecoins. After years of regular access to Tether's stablecoin platform, a rupture finally occurred earlier this month when Tether froze $23 million worth of Garantex's USDT balances at the request of law enforcement authorities. The move came in conjunction with a seizure by law enforcement of Garantex's website and servers.  Garantex's website was seized in March 2025 by a collection of law enforcement agencies. In a press release, Tether claimed that its actions against Garantex illustrated its ability to "track transactions and freeze USDt." But if Tether was so good at tracking its users, why did it connect a sanctioned party like Garantex in the first place, and continue to service it for over four years? Something doesn't add up. Not just Tether: other stablecoins offered Garantex access, too Tether doesn't appear to have been the only stablecoin platform to provide Garantex with access to its platform. MakerDAO (recently rebranded as Sky) and Circle Internet may have done so, too. Circle, based in Boston, manages the second-largest stablecoin, USDC. When OFAC put Garantex on its sanctions list in April 2022, Circle was quick to freeze one of the designated addresses. It did no hold any USDC balances. However, like Tether, Circle's no-vetting policy means that it doesn't do due diligence on users (sanctioned or not) who open new wallets, hold USDC in those wallets, and use them to make payments within the USDC system. Circle only checks the ID of users who ask it to cash them out. Thus, it would have been a cinch for Garantex to dodge Circle's initial freeze: just open up a new access point to the USDC platform. Which is exactly what appears to have happened. On March 30, 2022, Garantex used its Twitter/X account to announce that it was offering USDC-denominated services. Beginning at some point in the first half of 2022, close to the time that the U.S. Treasury's sanctions were announced, Garantex began to list USDC on its trading page (see screenshot at top). The exchange's trading page continued to advertise USDC-denominated financial services through 2023, 2024, and 2025 until its website was seized last month.  Tether, Circle's competitor, proceeded to freeze $23 million worth of USDT on behalf of law enforcement authorities, as already outlined. However, respected blockchain sleuth ZachXBT says that Circle did not itself interdict Garantex's access to the USDC payments platform, alleging that "a few Garantex addresses" holding USDC had not been blacklisted. MakerDAO is a geography-free financial institution that maintains and governs the Dai stablecoin, pegged to the U.S. dollar. Archived screenshots show that Garantex added Dai to its trading list by September 2020, not long after the exchange had enabled Tether connectivity. According to blockchain analytics firm Elliptic, Russian ransomware group Conti has used Garantex to get Dai-denominated financial services. Garantex is able to access the Dai platform because MakerDAO uses the same no-vetting model as Tether. In fact, MakerDAO takes an even more hands-off approach than the other stablecoin platforms: it didn't seize any of the original 2022 addresses emphasized by OFAC. That's because Dai was designed without freezing functionality. Not vetting users is lucrative Providing financial services to a sanctioned Garantex would have been profitable for Tether and competing stablecoin platforms managed by Circle and MakerDAO.  All stablecoins hold assets—typically treasury bills and other short term assets—to "back" the U.S. dollar tokens they have issued. They get to keep all the interest these assets generate for themselves rather than paying it to customers like Garantex. If we assume an average interest rate of 5% and that Garantex maintained a consistent $23 million in Tether balances over the 34 months from April 2022 (when it was sanctioned) to March 2025 (when it was finally frozen out), Tether could have earned approximately $3.2 million in interest courtesy of its relationship.  Not only does their no-vetting model mean that stablecoin platforms get to earn ongoing income from bad actors like Garantex, this model also seems... not illegal? Stablecoin legal teams have signed off on the setup, both those in the U.S. and overseas. Government licensing bodies like the New York Department of Financial Services don't seem to care that licensed stablecoins don't ask for ID, or at least they turn a blind eye. (Perhaps these government agencies are simply unaware?) Nor has the U.S. Department of Justice indicted a single stablecoin platform for money laundering, sanctions violations, or failing to have a compliance program, despite it being eleven years now since Tether's no-vetting model first appeared. The model seem to have legal chops. Or not? Banks and fintechs are no doubt looking on jealously at the no-vetting model. Had either PayPal or Wells Fargo allowed Garantex to get access to their payments services, the punishment would have been a large fine or even criminal charges. Sanctions violations are a strict liability offence, meaning that U.S. financial institutions can be held liable even if they only accidentally engage in sanctioned transactions. But more than a decade without punishment suggests stablecoins may be exempt. This hands-off approach benefits stablecoins not only on the revenue side (i.e they can earn ongoing revenues from sanctioned actors). It also reduces their costs: they can hire far fewer sanctions and anti-money laundering compliance staff than an equivalent bank or fintech platform. Tether earned $13 billion in last year with just 100 or so employees. That's more profits than Citigroup, the U.S.'s fourth largest bank with 229,000 employees, a gap due in no small part to Tether's no-vetting access model.  The coming financial migration? Zooming out from Garantex's stablecoin experience, what is the bigger picture?  I suspect that a great financial migration is likely upon us. Financial institutions can now seemingly provide services to the Garantex's of the world as long as the deliver them on a new type of substrate: decentralized databases. If so, banks and fintechs will very quickly shift their existing services over from centralized databases to decentralized ones in order to take advantage of their superior revenue opportunities and drastically lower compliance costs.  This impending shift isn't from an inferior technology to a superior one, but from an older rule-bound technology to a rule-free one. PayPal recently launching its own stablecoin is evidence that this migration is afoot. The argument many stablecoins advocates make to justify the replacement of full due diligence with a no-vetting access model is one based on financial inclusion. Consumers and legal businesses in places such as Turkey or Latin America, which suffer from high inflation, may want to hold digital dollars but don't necessarily have access to U.S. dollar accounts provided by local banks, perhaps because they don't qualify or lack trust in the domestic banking system. An open access model without vetting solves their problem.       What about the American voting public? Do they agree with this migration? The last few decades have been characterized by a policy whereby the government requires financial institutions to screen out dangerous actors like Garantex in order to protect the public. Forced to the fringes of the financial system, criminals encounter extra operating dangers and costs. The effort to sneak back in serves as an additional choke point to catch them. To boot, the additional complexity created by bank due diligence serves to dissuade many would-be criminals from engaging in crime. Is the public ready to let the Garantexes back in by default? I'm not so sure it is. Tether is available at Grinex, a Garantex reboot. [link] Garantex's stablecoin story didn't end with last month's seizures and indictment. According to blockchain analytics firm Global Ledger, the exchange has been renamed Grinex and continues to operate. Tether services are already available on this new look-alike exchange, as the screenshot above reveals. Global Ledger says that $29.6 million worth of Tether have already been moved to Grinex as of March 14, 2025.  This is the reality of an open-access, no-vetting financial system: bad actors slip in, eventually get cut off, and re-enter minutes later—an endless game of whack-a-mole that seems, for now at least, to be tolerated. It will only get larger as more financial institutions, eager to cut costs, gravitate to it.

We're all busy doing our best to boycott U.S. products. I can't buy Special K cereal anymore, because it's made in the U.S. by Kellogg's. But I'm still buying Shreddies, which is made in Niagara Falls, Ontario. Even that's a grey area, since Shreddies is owned by Post, a big American company. Should I be boycotting it? Probably. However, the disturbing thing is that I'm paying for my carefully-curated basket of Canadian groceries with my MasterCard. If we really want to avoid U.S. products, we can't just vet the things we are buying. We also need to be careful about how we are doing our buying. Our Canadian credit cards are basically made-in-U.S. goods. They rely on the U.S-based Visa or MasterCard networks for processing. Each credit card transaction you make generates a few cents in revenue for these two American mega-corporations. It doesn't sound like much, but when multiplied by millions of Canadians using their cards every day, it adds up. Vigilant Canadians shouldn't be using them. Canadians who want to boycott American card networks have two options. Go back to paying with cash, which is 100% Canadian. Or transact with your debit card. Debit card transactions are routed via the made-in-Canada Interac debit network.* We're lucky to have a domestic debit card option. Our European friends are in a worse position, since many European countries (Poland, Sweden, the Netherlands, Finland, and Austria) are entirely reliant on MasterCard and Visa for both debit and credit card transactions.  Unfortunately, going back to debit cards means doing without all of the consumer protection that credit cards offer in an online environment. Worse, you're giving up your credit card rewards or cash back. If you don't pay with your 2% cash back credit card, for instance, and use your debit card instead, which doesn't offer a reward, you're effectively losing out on $2 for every $100 you spend. This should illustrate to you, I hope, the golden shackles imposed on us by our U.S.-based credit cards. It's fairly easy to replace your American-grown tomatoes with Mexican ones or your U.S.-made car with a Japanese car. But networks, which tend towards monopolization, are not so easy to bypass. Which gets us into the meatier issue of national sovereignty. The difficulty we all face boycotting the MasterCard and Visa networks reveals how Canada has let itself become over-reliant on these critical pieces of U.S financial infrastructure. My fear is that our neighbour's political leadership is only going to fall further into authoritarianism and belligerence, eventually making a play to slowly annex Canada—not by invasion, but by "Canshluss". If so, this will involve using our dependencies on U.S. systems, including the card networks, to extract concessions from us. "Canada, if you don't do x for me," says Trump in 2026, "we're TURNING OFF all your credit cards!"  In anticipation, we need to remove this particular financial dependency, quick. We're already safe when it comes to debit cards; we've got Interac. But we need the same independence for our credit cards. More specifically, we need to pursue an end-goal in which all Canadian credit cards are "co-badged". That means our credit cards would be able to use both the Visa/Mastercard card networks and Interac (or, if Interac can't be repurposed for credit cards, some other yet-to-be-built domestic credit card network). With co-badging, if your credit card payment can't be executed by Visa because of a Trump freeze order, at least the Canadian network will still process it. This is how the French card system works. While much of Europe suffers from a massive dependency on MasterCard and Visa, France is unique in having built a 100% French card solution. The local Carte Bancaire (CB) network can process both French debit card transactions, like Interac can, but goes one step further by also handling French credit card purchases. Before paying for their groceries with a card, French card holders get to choose which network to use, the local one or the international one. THIS IS WHAT CANADA NEEDS: This French credit card, issued by Credite Agricole, is co-badged with the domestic Carte Bancaire (CB) network and the international MasterCard network. When incidents occur on one route (CB, for instance), traffic is automatically routed to the back-up route, MasterCard, and vice versa. I think that a Canadian solution to the Trump problem would look something like this French CB card. The incoming Carney government should move to co-sponsor a CB-style domestic credit card network along with the big banks (perhaps a simple upgrade to Interac will do?). All Canadian financial institutions that issue credit cards would be required to co-badge them so that Canadians can connect to this new network as well as Visa or MasterCard. Even if annexation never actually occurs, at least we've got a more robust card system in place to deal with outages arising from hacking or natural disasters. Along with France, we can take inspiration from India, which introduced their Visa/MasterCard alternative, Rupay, in 2012. Thirteen years later, RuPay is now a genuine competitor with the American card networks. I can't believe I'm saying this, but we can also use Russia as a model, which was entirely dependent on Visa and MasterCard for card payments until it deployed its Mir card network in 2016—in the nick of time before Visa and MasterCard cut ties in 2022. Europe will have to push harder, too. The EU has been trying to rid itself of its Visa and MasterCard addiction for over a decade now, without much luck. Its first attempt, the Euro Alliance of Payment Schemes, was abandoned in 2013.  (In fact, one of the reasons the European Central Bank is exploring its own digital currency is to provide an alternative to the American card networks.) As Canada builds out its own domestic credit card workaround, we can learn from the European mistakes. The U.S. is no longer a clear friend. Boycotting U.S. products is one thing. But if we truly want to reduce the external threat, we need to build our own card infrastructure—before it's too late. * In-person debit payments are processed by the Interac network. However, online debit card transactions default to the Visa or MasterCard networks. While Interac does allow for online purchases, many retailers don't offer the option, and when they do, the checkout process requires the user to log into their online banking, which is more of a hassle than using a card.

In what seems to be an effort to extort Canada for additional benefits, Donald Trump complained yesterday on social media that CANADA DOESN'T EVEN ALLOW U.S. BANKS TO OPEN OR DO BUSINESS THERE. And so according to Trump, Canada doubly deserves to be disciplined with tariffs. Well, if it's true that U.S banks aren't allowed to do business in Canada, then why in god's name is one of the U.S.'s largest banks doing business in downtown Toronto? Citigroup Place, 123 Front St. West, Toronto, Ontario, Canada Citi has been operating in Canada since 1919 and currently has 1,700 Canadian employees. According to OSFI, Canada's bank regulator, the bank earned C$35 million in Canada in the first three quarters of 2024 and has C$5.49 billion in Canadian assets as of September 30, 2024.  In short, Trump was either lying, misinformed, crazy, or some combination of those three. Canada allows foreign banks to enter our banking industry by requiring them to set up a domestic subsidiary and applying for a Schedule II banking charter. Schedule II banks can operate in all of the same lines of business as mainstay Canadian banks (i.e. Schedule I banks) like Royal Bank or Bank of Montreal. There are 16 Schedule II banks in Canada, three of which are American. (In addition to Citi, the other two are Amex Bank and JP Morgan.) Some folks on social media tried to reinterpret Trump's complaint: "But JP, what Trump really meant to say is that Canada doesn't allow U.S. banks to serve retail customers." As proof they cited the fact that if you walk into a Citi office in Canada, Citi won't allow you to open a personal chequing account. The reason that Citi won't give you a personal chequing account isn't because the rules prevent them from doing so. Rather, Citi (along with Amex and JP Morgan) have chosen not to enter the Canadian retail banking market, preferring to focus instead on other types of Canadian banking, like commercial and investment banking. If Citi, for instance, wanted to set up a retail branch network, it could. In fact, Citi once had a small five-branch retail banking network in Vancouver and Toronto, offering personal chequing and savings account, term deposits, loans, mortgages, mutual funds and RRSPs. But it sold out in 1999 to Canada Trust, which was ultimately bought by TD Bank. Other foreign banks have also set up Schedule II banks with a retail presence, only to sell out to domestic banks. HSBC Canada, owned by its British parent, became Canada's seventh largest bank—one that was notably successful in offering mortgages to retail customers—but was recently offloaded by its parent to Royal Bank, a Schedule I bank. ING Canada, owned by Dutch-based ING Bank, created one of Canada's most popular discount retail banks, ING Direct, but sold it to Scotia Bank in 2012, which rechristened the discount bank Tangerine Bank. The lone Schedule II foreign bank I'm aware of that still serves retail customers is ICICI Bank, which is owned by its Indian parent. Why are U.S. and foreign banks reticent to compete in Canada's retail banking market? Contrary to perceptions that Canadian banking is slow and lazy, it's actually quite difficult to make much headway in Canada. The Big-5 banks, plus National Bank, which counts as half a big bank, have built strong retail branch networks that span the entire country. They compete rigorously for consumer deposits, offering higher interest rates than U.S. banks offer to Americans, suggesting a more cut-throat market than south of the border. In short, U.S. banks don't have the cojones to cross the border and compete head-to-head against Canada's more competitive behemoths. Citi already tried. It gave up. By contrast, the U.S. is an easier market for a foreign bank to enter because its banking industry is more fragmented. And many Canadian banks have entered, with TD Bank and Bank of Montreal occupying 10th and 13th spot respectively on the list of largest U.S. banks. This fragmentation is the residue of the U.S.'s refusal (until recently) to allow banks to set up branches across state lines. By contrast, Canada has always had fairly permissive rules about establishing cross-country banking networks. The irony here is that Trump's complaints about lack of openness best apply to the U.S., historically the culprit when it comes to tamping down the spread of banking. Canadian banks' U.S. and international exposure has increased over time. A recent Bank of Canada study finds that our banks now have more foreign liabilities (i.e. deposits) than domestic liabilities. (See chart below). More precisely, 57% of all Canadian banks' liabilities are now foreign. As for our banks' asset mix, foreign assets are poised to surpass domestic assets in the next year or two, if trends continue. Rising Canadian bank exposure to the rest of the world. Source: Bank of Canada The reason for this outward migration is clear. Canada's saturated retail banking market offers few opportunities for growth, but other parts of the world are less saturated, and so these jurisdictions offer Canadian banks ideal avenues for acquisitions and growth. This gives us an additional vantage point for viewing Trump's absurd comments about Canadian banking. He may not be saying that Canada's banking system is closed, but that the U.S. banking system is now effectively shut off to additional acquisitions by Canadian banks, as part of some sort of America First banking policy. This implicit threat of a foreign banking blockade may explain, in part, why the price of Canadian bank stocks fell so much more than the broader Canadian market yesterday. Their avenues for growth may have just narrowed.

On Twitter/X, I recently suggested that the network effects of the stablecoin market are massive. Tether, which has four times more wallets than all other stablecoins, is locked-in as the stablecoin lingua franca, just like English has been locked-in as the global language of business.  In case you've missed the trend, stablecoins are fiat money (primarily U.S. dollars) that are issued on a new type of database called a blockchain. The total value of stablecoins in circulation has grown from $0 to over $200 billion in a decade, with Tether dominating at $138 billion. When I said at the outset that the stablecoin market is governed by network effects, what I meant is that a positive feedback loop exists whereby the value that a network (i.e. languages or stablecoins) provides to users increases as more users join the network. Once a given stablecoin has entered into this virtuous loop, other issuers cannot join in, and will have troubles competing. It's a winner take all market that Tether and its stablecoin USDt (and perhaps smaller competitor USDC, issued by Circle) have already won. Larry White, a monetary economist who I've mentioned a few times on my blog, asked me why I think network effects are present in the stablecoin market. We don’t see network effects with other U.S. dollar payment media like checkable deposits, Larry points out (and I agree), so it's not clear why we should see this with stablecoins. Here's my logic. Stablecoins aren't fungible, bank deposits are The key is that while U.S. dollar stablecoins—Tether's USDt, Circle's USDC, PayPal USD, etc—are pegged to the dollar, and thus seem to be alike, they are not actually completely alike. That is, they are not fungible with each other.  Fungibility is one of my favorite words, and I write about it quite often on this blog. It means that members of a population are interchangeable, or perfectly replaceable with each other. All grams of pure raw gold are interchangeable. Not all grams of pizza are alike—pizza is non-fungible. U.S. dollar bank deposits (say Well Fargo dollars and Chase dollars) are fungible with each other. Rather than being independent, they are fused together as homogeneous and singular U.S. dollars. A Chase dollar is just as good as a Wells Fargo dollar for the purposes of making payments. That's not the case with stablecoins, which are like pizza. Or better yet, in the same way that Chinese yuan and UAE dirham are pegged to the dollar but remain independent currencies, each U.S. dollar stablecoin is pegged to the dollar but functions as its own distinct non-fungible currency. For the purposes of making payments, one stablecoin is not as good as another one, just like how dirham balances aren't perfect replacements for yuan. The reason behind this difference is that U.S. banks cooperate with each other by accepting competitor's money at par on behalf of their customers. For instance, I can take a Wells Fargo check to my Chase branch and Chase will accept it 1:1 even though it represents a competing bank's dollar. Or I can send an ACH payment directly from Wells Fargo to Chase, and Chase will accept that Wells Fargo dollar at par and convert it into a Chase dollar for me.  The effect of this reciprocal acceptance is that all U.S. banking dollars are tightly knit together, or interchangeable. A fungible standard has been created. I can't perform these same actions with stablecoins. I can't send 100 USDC to Tether to be converted into 100 USDt, nor send 100 USDt to Circle, which issues USDC, to be converted into 100 USDC. Stablecoins issuers are loners. They've chosen to avoid banding together to weave a unified U.S dollar stablecoin standard. This lack of standardization explains some weird things in the stablecoin market, like why there are so many markets to trade USDt for USDC (see below). Notice that the clearing price in these stablecoin-to-stablecoin markets is never an even $1, but always some inconvenient price like 0.991 or 1.018. Some of the multiple markets for trading USDt for USDC, all at varying prices Source: Coingecko   There is no equivalent trading market for Chase-to-Wells Fargo balances or TD-to-Bank of America dollars. These banks' dollars are perfectly compatible and don't require such markets. The advantages of a single dollar standard Harmonization is useful. Anyone can walk into a McDonald's and purchase a Big Mac for $5.69 with whatever brand of bank dollar they want. Money held at small banks is just as useful as money at massive ones: the Bank of Little Rock may only have five branches, but its dollars are accepted at McDonald's all across the world, on par with those of Chase, America's largest bank. McDonald doesn't accept stablecoins, but if it did, it would have to offer multiple prices for a Big Mac: i.e. 5.73 USDt and 5.68 USDC. Each stablecoin serving as its own particular unit of account is inconvenient, both for McDonald's and its customers. PayPal USD probably wouldn't even be accepted at McDonald's: it's too small. The lack of standardized stablecoin market becomes even more awkward in asset markets. If you want to buy $1 million bitcoins on, say, Binance, there's a whole array of different U.S. dollar stablecoin markets available, including bitcoin-to-USDt, bitcoin-to-USDC, and bitcoin-to-FDUSD. (FDUSD refers to First Digital USD, a medium sized stablecoin.) The table above shows the prices of bitcoin and ether on Binance, the world's largest crypto exchanges. Notice that liquidity in both Binance's bitcoin and ether trading market is compartmentalized into different stablecoins rather than being fused into a single homogeneous US dollar-to-bitcoin market. Source: Coingecko You can forget about easily buying bitcoins with PayPal USD stablecoins. No crypto exchange offers that trading pair; PayPal USD is too small to be worth the hassle. This has the effect of fragmenting the liquidity of the stablecoin market into different buckets. Instead of stablecoins-in-general having a certain level of marketability, each individual stablecoin has its own distinct liquidity profile in asset markets. In contrast, the liquidity that a Wells Fargo dollar, a Bank of Little Rock, or a Chase dollar provides to their owner in the context of asset markets has been unified into a collective whole. If you want to buy shares of Blackrock's iShares Bitcoin ETF, there isn't a separate market for Wells Fargo-to-bitcoin or Chase-to-bitcoin. As for Bank of Little Rock dollars, they are just as fit for bitcoin purchases as its much largest competitors. A winner-takes-all market Now we can understand why network effects dominate the stablecoin market. If you want to start using stablecoins to trade crypto or buy stuff, you will always be arm-twisted by market logic into choosing the largest most liquid stablecoin. And your decision to go with the largest one makes that stablecoin a little more liquid, thus solidifying its pole position. Selecting a smaller stablecoin like PayPal USD makes little sense. McDonald's will never accept it, and there are many crypto assets that you won't be able to buy with it. Even when certain PayPal USD trading pairs are available, the bid-ask spreads will be wide, imposing much larger costs on you than if you simply went with a larger stablecoin. Thus network effects, working in reverse, repel uptake of PayPal USD. The unsafe stablecoin is the largest Tether remains the largest stablecoin, despite being one of the most unsafe stablecoins. (USDC does not get top marks for safety, either.) Network effects explain this. Stablecoin rating agency Bluechip awards Tether a D rating, noting that it is "less transparent and has inferior reserves... USDT is not a safe stablecoin". Under normal conditions (i.e. those not characterized by network effects) the safest stablecoins would have long-since displaced Tether from its leading spot. But in stablecoin markets, the safest stablecoins—Gemini USD, PayPal USD, and USDP, all rated A or A- by Bluechip—remain insignificant players. The virtuous circle in which Tether is locked dominates all other factors. These are the best-ranked fiat stablecoins according to Bluechip. But they are also tiny, with market capitalization below $1 billion. There appears to be no point trying to be a safe stablecoin, since the network effects arising from liquidity completely dominate any safety concerns that users might have. Eyeing Tether's profits, new competitors are entering the stablecoin market. But this is a game they probably shouldn't bother playing. PayPal arrived last year with PayPal USD, but to date it remains mostly irrelevant, despite huge growth in the overall stablecoin market over the same period. Ripple and Revolut are also slated to bring out their own products. They're also destined to mediocrity, because they're too late to make the jump into the virtuous loop that Tether and (to a lesser extent) Circle occupy.  (There is one caveat. Should one of the two leaders eventually be shutdown for money laundering offenses or sanctions evasion, one of these also-rans could be vaulted into their spot.) Might the stablecoin sector eventually migrate over to the unified fungible standard that characterizes banking deposits?  No, that's probably not going to happen. For a fusion to occur, Tether and runner-up Circle, which issues USDC, would have to start accepting their competitors' stablecoins at par. But they won't go down this path, since that would kill off the network effect that gives them their unrivaled dominance over the rest of the pack. No, it's in the interests of the leaders for chaotic non-fungibility to continue.  Alas, this lack of standardization may limit the stablecoin sector's broader potential to serve as a cohesive global payment alternative to the better-organized banking standard. Sometimes a bit of cooperation trumps competition.

The next chapter in the Tornado Cash saga just dropped. Last week a court ruled last that Tornado Cash, a bot that can be used for obfuscating crypto, is safe from being sanctioned. I first wrote about Tornado Cash in 2021, before its legal troubles began, warning of the risks ahead. I've been tracking Tornado's legal saga since then. (See here | here | here ). The saga serves as a bellwether for how financial services hosted on blockchains are to be sliced and diced under existing laws, in particular the crucial anti-money laundering statutes and sanctions laws. More generally it foreshadows how autonomous techno-beings, many of which don't yet exist, are to be treated by the law. In the newest chapter of the saga, a court ruled that America's sanctions authority, the U.S. Treasury's Office of Foreign Assets Control (OFAC), does not have the authority to sanction a certain type of smart contract, or string of autonomous code, that undergirds Tornado Cash: its so-called immutable contracts. Recall that in August 2022, OFAC sanctioned Tornado Cash, which accepts traceable crypto from users and returns it in untraceable format. Tornado had been used by the sanctioned North Korean hacker group Lazarus to obfuscate its financial tracks. OFAC listed Tornado Cash's website tornado.cash along with 53 Ethereum addresses. The sanctions were relatively effective. Americans could no longer use the bot without risking fines or imprisonment. Those who had funds deposited in Tornado had to ask OFAC for special permission to withdraw them. In the months after the sanctions were announced, usage of the privacy bot plunged and the amount of crypto deposited fell by over half.   After two different sets of plaintiffs challenged OFAC's actions in court, the appeals court in one of the cases returned a verdict last week. An immutable smart contract is "unownable, uncontrollable, and unchangeable—even by its creators," and therefore it doesn't qualify as property. Because OFAC's sanctioning power is limited to that which is property, it follows that OFAC cannot sanction immutable smart contracts. This not-property ruling only applies to twenty immutable Tornado Cash contracts that were on OFAC's sanctions list. Tornado's mutable contracts, those that can be controlled and changed, remain property—and thus can stay on the list of sanctioned contracts. Unless OFAC wins on appeal, it will presumably have to unsanction those twenty immutable contracts. Now, it's possible that as long as the remaining sanctioned mutable contracts are crucial to the functioning of the Tornado Cash bot, the revised sanctions blacklist will still have an effect. And if OFAC adds other key mutable Tornado Cash smart contracts to its list (say like the contracts allowing governance, which for some reason were not originally sanctioned), American users will continue to steer clear of Tornado Cash, the bot's anonymizing capacities remaining lower than otherwise, thus diminishing its ability to serve North Korean interests.  But if not, what can OFAC do?  Sanction users, not code I've already done a bit of digging on this question. In response to the sanctions, I wrote an article in late 2022 entitled: How to stop illegal activity on Tornado Cash (without using sanctions) The gist was to explore alternative tools for countering illicit activity on Tornado rather than the blunt tool of sanctioning its actual smart contracts. What I suggested was to apply pressure to the users of the smart contracts. "Rather than punishing code, penalize the people who use the code." The logic goes like this. Any user who deposits crypto to Tornado Cash, even someone with clean crypto, is providing North Korea with prohibited financial services, the Tornado bot being the means by which the two sides are connecting as counterparties. Whether intentional or not, a user's deposits broaden the anonymity set of Tornado Cash, or its ability to obfuscate larger amounts of illicit funds sourced from sanctioned counterparties like Lazarus. Think of it as sanctioned North Korean users passing on sanctions taint to all other Tornado Cash users by virtue of everyone interacting via the same bot, Tornado Cash. This taint spreads to those who deposited their crypto (clean or dirty) to Tornado at the same time as Lazarus and/or those who have continued to deposit to it in light of the known fact that the North Korean group regularly deposits stolen funds to the platform. OFAC issues a public alert stating that any foreigner can and will be sanctioned if their funds interact with North Korean funds on Tornado Cash. In response, some foreign users will risk being designated and continue to engage with Tornado. Many will not. As for U.S. users, OFAC can threaten them with potential civil monetary penalties if they aid North Korea using Tornado as their a tool. A $10,000 fine for interacting with sanctioned North Korean actors via the Tornado Cash bot will probably discourage most usage. Another core set of Tornado Cash users who OFAC has legal leverage over are the relayers—real life individuals who provide an extra layer of privacy to Tornado Cash users. (I explain here why relayers are necessary for full privacy). OFAC can threaten foreign relayers with sanctions and U.S.-based relayers with civil monetary penalties. Pressuring these various groups of users won't stop Tornado Cash code from functioning, but it will certainly constrain the activity it facilitates, and thus make it harder for North Korea to anonymize its funds. And it is consistent with the court's not-property ruling because users, not contracts, are being targeted. I'm not saying that OFAC will follow this playbook, or that it should, but it certainly is an option. There is another route, though, and that is to go to Congress and ask for the ability to put sanctions on immutable entities.  More broadly, Tornado Cash may just be the first in an emerging population of unownable and uncontrollable techno-beings—bots, machines, drones, androids, AI agents,  automatons, and golems—that operate independently of human control, many of which will end up doing very dangerous things. Society may want the legal ability to protect its members from these immutable contraptions, including by sanctioning them. For instance, imagine the following scenario... A Russian AI-guided assassin bot If a Russian assassin is regularly poisoning people (including U.S. citizens) for criticizing Putin, OFAC can sanction that assassin, thus preventing any American entity from dealing with him and blocking all of his accounts, his car, and his interests in various companies. That might not stop the assassin, but it'll make his job more difficult. In doing so, OFAC is simply fulfilling its mandate to use its sanctioning powers to protect Americans. Say the assassin creates an artificial intelligence and imbues it with all of his assassin's lore, providing it with an artificial body and then throwing away the keys, rendering the robot immutable. The court's recent not-property ruling suggests that while OFAC can ably defend Americans from the flesh and blood assassin, it cannot protect them from the assassin's immutable killing robot—even though the robot performs the precise same killing function as the living assassin using the exact same techniques. This is obviously an incongruity, one that seems like it should be fixed. Or is there a specific reason why we should provide legal safe harbor to all unownable and uncontrollable techno-beings? Feel free to explain in the comments. In any case, OFAC's efforts to apply its national security mandate to Tornado Cash are probably not over. Let's see how it responds. Some sort of resolution is important because we are still in the early stages of being inundated with self-guided autonomous agents.