An Irresistible Target: North Korea’s Use of Cryptocurrency to Fund the Regime

By Lauren Jackson, Former Legal Research Intern
Edited by Rosa Park, HRNK Director of Programs and Editor, and Benjamin Fu, HRNK Research Intern

June 23, 2020

The growing field of cryptocurrency is the new forum for rogue states and bad actors to earn a profit and finance criminal activities. Due to the largely unregulated and unsecured nature of the crypto industry as it stands today, there are very few consequences for stealing cryptocurrency. North Korea has exploited this vulnerability, and experts believe that the Kim regime exchanges coins for currency or physical goods to finance and support its leadership as well as nuclear and ballistic missile programs.[1] If North Korea is able to gain a steady revenue of funds from cryptocurrency, then the regime will continue to perpetrate human rights abuses. North Korean leadership will have no financial incentive to end its human rights violations if the country’s cybercrimes involving cryptocurrency render sanctions useless. Skirting sanctions enables North Korea to maintain its gulags, to keep its borders closed, and to continue to isolate its citizens from the rest of the world.

​North Korea Turns to Cryptocurrency

After the United Nations Security Council imposed sanctions on North Korea’s oil supplies and textile industry in September 2017, North Korea turned to cryptocurrency to make up for its losses once the sanctions were enforced.[2] 

Cryptocurrency is a digital currency without a central authority such as a bank.[3] Cryptocurrency bypasses the payment and money-tracking mechanisms traditionally utilized to make cash transactions. For example, say a shopper wants to purchase a sofa on Overstock.com. Typically, the shopper needs a debit or credit card issued by a bank or credit card association. Once the shopper has submitted his or her card information, the bank or card issuer is notified of the transaction and either accepts the transaction as legitimate or declines the transaction entirely. This third-party bank or card issuer is responsible for keeping track of the amount held in the account or credit available as well as any transactions depositing or withdrawing from the account. Typically, the third-party uses a central server to keep a ledger of the information.[4] Cryptocurrency, however, completely removes the bank or card issuer from the transaction. Say the same shopper wants to buy the sofa using Bitcoin instead, a cryptocurrency accepted by Overstock.com.[5] The shopper retains full control over his or her money, and the transaction never passes through a third party. Overstock.com can receive the payment without using a central server, much like a peer-to-peer file-sharing network.[6] 

Since there is not a central server that records and verifies these transactions, cryptocurrency utilizes blockchain technology that allows every user on the network to have access to a ledger containing all transactions using a particular cryptocurrency.[7] The software algorithms record the transactions across the network and confirm the validity of these transactions.[8] This form of currency is particularly attractive to North Korea because “it can be moved quickly and anonymously across borders and can be used to buy goods and services online or converted to hard currency.”[9] Due to the depletion of resources and income stemming from the sanctions, North Korea is increasingly relying on cryptocurrency obtained usually through illegal means.

North Korea’s Means of Gaining Cryptocurrency

Even prior to the increased sanctions, North Korea had already begun mining cryptocurrency. “Mining” is the method by which a particular transaction is verified as being legitimate and accurate. A “miner” is responsible for this verification process by competing against other miners to compute an accurate number chain identifying the transaction. The miner who correctly computes the number chain first is rewarded with cryptocurrency, most popularly Bitcoin. Monero is another attractive cryptocurrency to mine for those who wish to remain anonymous because Monero uses confidential transactions and stealth addresses to “obfuscate transactions at the protocol level to protect both senders and receivers from eavesdropping while still allowing transactions to be validated by a third party if desired.”[10] Conceptually, anyone could be a miner; however, mining requires a significant amount of computing power to be the first to accurately predict the number chain. This is a legal method of creating cryptocurrency that is being used and manipulated by North Korea. 

According to Recorded Future, an international technology company focused on researching threat intelligence, North Korea began mining as early as May 2017.[11] Since then, North Korea’s exploitation of mining cryptocurrencies has “exploded.”[12] AlienVault, a US cybersecurity firm investigating North Korea’s mining activities, discovered a software that installs code for mining and sends the generated coins to a server at Kim Il Sung University in Pyongyang.[13] In order to be the first to solve the puzzle, North Korea began hijacking computers to support this mining capability.[14] Since mining takes a significant amount of money, hardware, and electricity, using someone else’s computer power circumvents the difficulties and costliness of mining. According to Chris Doman, an AlienVault threat engineer, “[R]unning [the mining software] on someone else’s computer means you don’t have any costs, only profit.”[15] The Korea Development Bank reports that Joseon Expo, a North Korean IT firm, has already developed the software technology to engage in cryptocurrency transactions.[16]


North Korea not only mines cryptocurrency, but also employs illegal means of creating wealth through cryptocurrency. In May 2017, North Korea hacked into businesses’ computer systems worldwide through ransomware downloaded onto employees’ computers. These attacks have been deemed the “WannaCry Attacks” named for the ransomware software used to break into the computer system. After the break-in, North Korean hackers were able to cause chaos on the businesses infected with the ransomware, particularly health service providers in the United Kingdom.[17] 

In order to regain control of its computer systems, the victims had to pay a ransom into one of three Bitcoin wallets.[18] At the time, there was criticism of the attackers by the information security community because it seemed naïve to only use three wallets, which are easily traceable. At the end of the attack, there were 52 Bitcoin in the wallets, which did not move until August 2, 2017. The wallets were emptied in a total of six transactions.[19] The Bitcoins were then moved into a technology called a mixer. A mixer is a legal coin launderer that breaks up cryptocurrency into tens of thousands of pieces and engages in tens of thousands more transactions in order to obfuscate the original coins.[20] After the coins were run through the mixer, North Korea transferred the coins into Monero, a cryptocurrency that allows only the sender and the receiver to know who each other are and how many coins are part of the transaction, making the coins difficult to trace.[21] Monero issues users a “stealth address,” which prevents transactions from being linked to a specific account.[22] Monero also groups several hundred transactions on its network.[23] By lumping transactions together, the amount of cryptocurrency exchanged in each transaction is difficult to know.

Ransomware attacks are not the only tool used by North Korea to illegally generate Bitcoins. North Korea steals cryptocurrency from other countries by targeting their coin exchanges. South Korea, in particular, has been hit with a series of attacks on its coin exchanges. Most recently in June 2018, Bithumb, a South Korean coin exchange, lost $31.5 million to North Korean hackers.[24] Youbit, another South Korean exchange, filed for bankruptcy after two hacking attacks in 2017, depleting 17% of its assets.[25] Japan’s Coincheck suffered a staggering loss after hackers stole $530 million.[26] According to Recorded Future, North Korea’s total revenue from these cyber crimes can range anywhere from $500 million to $700 million, depending on when the country cashed out.[27]

North Korea is receiving a substantial payload from these cryptocurrency crimes and is unlikely to end its criminal behavior in the near future. Since the crypto industry remains largely unregulated and only lightly secured, cryptocurrency becomes an “irresistible target” for many bad actors.[28] In order to curb the loss of cryptocurrency and, in turn, reduce the amount of money North Korea can use to fund its regime, certain regulatory measures must be utilized. 

Response to Attacks and Regulations Enforced
    
Due to the decentralized and unregulated nature of cryptocurrency that is attractive to cybercrime, countries have been forced to respond to the growing threat of cybercrime in various ways. Some countries, such as Brazil and China, have hardline laws against cryptocurrencies. These states do not recognize coins as a financial asset and ban investments in cryptocurrency entirely.[29] However, countries are increasingly recognizing cryptocurrency as either a currency or a commodity, and enact policies accordingly.
    
South Korea

South Korea has been forced to grapple with the realities of cryptocurrency crimes, especially because the country is a major player in the cryptocurrency market. South Korea accounted for up to 15% of Bitcoin trading as of January 2018, and, according to one study, 80% of South Korean investors have profited from cryptocurrency.[30] The study also found that one-third of salaried Koreans invest in cryptocurrency with the average investor holding approximately $5,000 in cryptocurrency assets.[31] Once coin exchanges were exposed to attacks, Park Sang-ki, the justice minister, announced plans to halt cryptocurrency trading.[32] This announcement caused a plummet in the stock market and resulted in over 215,000 people signing a petition that opposed an all-out ban.[33] 

Instead of a complete ban on cryptocurrencies, South Korea adopted a ban on anonymous trading, which allows banks to comply with anti-money laundering and know your customer obligations.[34] An account at a virtual currency exchange must be linked to a real-name bank account in order to be used for deposits and withdrawals.[35] All foreigners and minors were also banned from being able to open new bank accounts linked to cryptocurrency accounts.[36] Furthermore, South Korea announced that the government will be taxing cryptocurrency exchanges at a rate of 24.2% on cumulative exchanges over 20 billion won annually.[37] In May 2018, there was speculation that South Korea would begin softening its cryptocurrency policies to align with forthcoming G-20 recommendations, if the recommendations from the G-20 central bankers and finance ministers were significantly less stringent than South Korea’s current policies.[38] The belief is that if South Korea unifies its policies with those of other countries, the unity will stabilize and expand the cryptocurrency market.[39]

While these regulations will cut against a bad actor’s ability to transfer coins without trace, hacking and coin theft is still a problem for South Korean coin exchanges. In June 2018, hackers attacked South Korea’s Coinrail, contributing to a 10% decrease in Bitcoin’s price immediately afterward.[40] Regulations on an exchange’s practices need to cut deeper than just their customer base. Regulators should also require coin exchanges to keep updated security measures. Naeem Aslam from ThinkMarkets, an online trading platform, said that the hacking pattern is “the result of loose regulatory control, and regulators must step in to protect the consumers. Anyone who wants to do anything with exchanges should be forced to adopt high-grade security and regular security upgrades.”[41]

United States

No single federal government agency regulates cryptocurrency currently.[42] Instead, a variety of agencies approach virtual currency in different ways. The Federal Reserve Bank sets the monetary policy, but the United States does not yet see cryptocurrency as a legal tender.[43] The Internal Revenue Service categorizes digital currency as property, subjecting cryptocurrency to taxation.[44] Potentially, cryptocurrency could become subject to anti-money laundering laws, and the Financial Crimes Enforcement Network (FinCEN) would then become responsible for enforcing the Bank Secrecy Act and passing regulations to ward off bad actors. FinCen has already applied these rules to initial coin offerings activities.[45] However, with no clear set of standards for virtual currency, the regulatory landscape remains uncertain. An article published in the Harvard Business Review states that, “[O]verlapping oversight by various agencies creates a structural barrier to change and drives up costs for creators of cryptocurrencies. This improvised approach needs to be improved.”[46] Not only is the lack of regulation a haven for bad actors, but the lack of regulation also hurts innovation, investors, and self-regulation within cryptocurrencies.[47]

Even though cryptocurrencies suffer from a lack of federal regulation, states have passed their own laws regulating virtual currency.[48] For example, Washington state requires cryptocurrency exchanges to maintain cash equivalents to an exchange’s transactions. The New York State Department of Financial Services established regulations that require virtual currency businesses to hold a license in order to operate in New York state.[49] This license has several compliance requirements and a $5,000 application fee.[50] Some cryptocurrency businesses were unable to comply with the regulations or found the application fee too expensive, which led to “The Great Bitcoin Exodus.”[51] With other states not implementing similar regulations, it was easy for businesses to move elsewhere. Arizona is attempting to pass a Bitcoin bill to allow state residents to pay taxes in Bitcoin.[52] Illinois and Georgia are looking to do the same thing, effectively making Bitcoin a legal tender. The failure of the federal government and state governments to align on a cohesive view of virtual currencies allows for bad actors to bypass consequences.

It is important to note that regulation is not the only way the United States has addressed North Korea’s cybercrimes. Identifying bad actors and pursuing criminal legal action against them is another tool the country can use to punish cybercriminals and deter others from committing similar crimes. After the Sony hacks, the Department of Justice brought a criminal complaint naming a North Korean hacker and identifying a team of hackers from North Korea’s main intelligence agency amongst others in “the most specific public accounting yet of North Korea’s cyberattacks against other countries.”[53] 

Other Countries

The European Union and the United Kingdom followed South Korea’s lead and implemented several regulations. In December 2017, the United Kingdom Treasury and the European Union made plans to end anonymous trading aimed at reducing money laundering and tax evasion.[54] In April 2018, the European Parliament passed a regulation that now requires exchanges to be registered with authorities, apply due diligence procedures on its customers, and report suspicious activity.[55]

Japan is leading the way in terms of cryptocurrency regulations, specifically because it has been the target of attacks in the past. Japan implemented new terms in its Payment Services Act. The Act defines virtual currency as a form of payment, although it stops short of defining coins as legal tender.[56] The Act also requires exchanges seeking to do business in Japan or with its citizens to register with the Financial Services Agency. Much like licensed exchanges in New York, Japanese exchanges must “maintain proper bookkeeping, undergo annual audits, file business reports and comply with strict know-your-customer and anti-money-laundering rules, and more.” At the time North Korea hacked Coincheck, the exchange was operating under a grace period and had not yet fully complied with the regulations in the Payment Services Act.[57] Most importantly, in April 2018, Japan launched the Japan Virtual Currency Exchange Industry Association. This association is a self-regulating body comprised of the first 16 licensed Japanese coin exchanges. This self-regulating body has the power to create rules, enforce them, fine violators, and develop standards for the industry.[58]

FATF Recommendations 
    
In an effort to create a unified vision of the future of cryptocurrencies, the world’s top 20 major economies asked for international organizations to weigh in on cryptocurrency standards in the March 2018 G-20 meeting. The G-20 meeting recommended that all countries should adopt cryptocurrency because it is “no longer possible to separate the digital age from the economy.”[59] Regulations are both inevitable and much-needed, but countries cannot ban cryptocurrencies outright.[60] The Financial Action Task Force (FATF) and the Organization for Economic Cooperation and Development are in charge of writing these policy goals into a proposal, specifically focusing on preventing crimes like financing terrorism, money laundering, and scams.[61]

The FATF report focused on investigation procedures and holding exchanges legally accountable. The report stated that the FATF will work on improving the implementation of anti-money laundering standards “by holding countries accountable for failures to address AML/CFT [anti-money laundering/combating the financing of terrorism] deficiencies through its mutual evaluation, follow-up, and International Cooperation Review Group processes.[62] The FATF report also highlighted the significance of innovation within the virtual currency regulatory framework. FATF prioritized working with the FinTech and RegTech community to develop digital identity technology that manages the risks of financing terrorism and money laundering.[63]

United Nations Resolutions on Cybercrime

More generally, the United Nations has sought to advance world cooperation in fighting against cybercrime. The United Nations Office on Drugs and Crime defines cybercrime as crime that “requires an ICT infrastructure and is often typified as the creation, dissemination and deployment of malware, ransomware, attacks on critical national infrastructure…and taking a website offline by overloading it with data…”[64] North Korea’s cryptocurrency-related offenses, its use of malware and ransomware, and its attack on several countries’ infrastructure fits squarely within the definition set out by the United Nations. 

Under the Commission on Crime Prevention and Criminal Justice Resolutions 22/7 and 22/8, the Global Programme on Cybercrime was tasked with assisting Member States “in their struggle against cyber-related crimes through capacity building and technical assistance.”[65] The main objective of the Global Programme is to aid in the investigation, prosecution, and adjudication of cybercrime “within a strong human-rights framework.”[66] Additionally, the Global Programme’s mission is to create an efficient government response to cybercrime and to strengthen communication between government, law enforcement, and the private sector about cybercrime.[67]

Potential Solutions

The only way to completely ensure safety and security would be to ban ownership of cryptocurrency outright. However, this solution is not possible in the United States with a free market, and there would be tremendous backlash from users and investors in cryptocurrency and blockchain technology. Regulation is the only other effective means of providing stability and security to the cryptocurrency industry.

Regulation is not the death of cryptocurrency. Instead, regulation can help with security in the cryptocurrency world, allowing investors and innovators to enter the field with more certainty and give assurances that their time and money are not frivolously spent. Regulation also wards off bad actors and sets consequences for those who may abuse the system. North Korea, as well as others who use virtual currency to finance crime, will continue to exploit this vulnerability for their own financial gain unless governing bodies enforce stricter standards of operation.

In order to protect valuable assets from bad actors, the United States should first come to terms with the state of cryptocurrency today. As more and more retailers accept cryptocurrency as a cash equivalent and cryptocurrency grows in popularity and use, the United States should recognize certain virtual currencies as legal tender. One of the key recommendations made in the G-20 meeting was to mainstream cryptocurrency. Not only does accepting cryptocurrency as legal tender benefit the United States by keeping its monetary policy in line with the modern age, but the cryptocurrency industry also encourages this mainstreaming.[68] States have already begun to recognize the monetary value of cryptocurrencies, and federal recognition would help legitimize and expand cryptocurrency and blockchain technology. Coin exchanges would become responsible for applying anti-money laundering laws and know your customer regulations within their operations. Notably, a coin exchange using a mixer would be responsible for making sure bad actors do not abuse mixer technology to launder coins or remain largely anonymous. If a platform already provides a high degree of anonymity, the use of a mixer is at best redundant and at worst furthering criminal activity. Since there are very few good-faith reasons why coins would need to be run through a mixer, a regulation banning mixers altogether may be wise to pursue. 

Most importantly, the United States should accept the recommendations of the FATF report and adopt similar policies like Japan by implementing a self-regulating body to respond to the crypto industry’s needs quickly and efficiently. Since no one agency currently oversees regulating cryptocurrency or the developing technology, coin exchanges, investors, and entrepreneurs do not have a set standard to meet. Uncertainty works in a bad actor’s favor, much like it has for North Korea. A self-regulating body that has a vested interest in keeping cryptocurrency legitimate can help secure the industry.

Coin exchanges should be held accountable for its security measures. FATF recommended legal consequences for not keeping security up-to-date. By requiring coin exchanges to comply with security measures set by a self-regulating body and encouraging the FinTech and RegTech industry to grow, the United States would be signaling its commitment to keep hackers and terrorists at bay from its citizens’ financial assets. 

Finally, the Global Programme on Cybercrime should consider North Korean cryptocurrency-related crime as a violation of the human-rights framework it is charged with upholding. Sanctions are no longer an effective means to undermine the regime’s ability to finance its most egregious human rights violation—political prison camps. The Global Programme should investigate all cryptocurrency theft and coin exchange attacks and advise Member States in order to strengthen the international community’s response to cybercrime.

Conclusion

As cryptocurrencies grow in popularity, countries must enact regulations that properly address the growing threat of cybercrime that cryptocurrencies present. Bad actors and hackers like the ones North Korea employed during the Sony and Wanna Cry attacks use their coins to skirt sanctions and counteract depleted funds. The United States should support policies that acknowledge the relevance of cryptocurrency as legal tender and create a self-regulating body that can respond to the industry’s growing need for regulation. Cryptocurrency has the potential to greatly benefit the United States, but, as North Korea has demonstrated, the industry is a haven for cybercriminals to exploit.
​
Lauren Jackson is an attorney practicing in tax and corporate law in Virginia Beach, Virginia. She graduated from Liberty University in 2014 with a BA in English and minors in Journalism and Writing. In 2019, Lauren graduated from the University of Toledo College of Law, where she published a Law Review article about the detention of refugees in prison camps on Manus Island and Nauru. Lauren interned with the Committee for Human Rights in North Korea during the summer of 2018.

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[12] Priscilla Moriuchi, “North Korea’s Ruling Elite Adapt Internet Behavior to Foreign Scrutiny,” Recorded Future (blog), April 25, 2018, https://www.recordedfuture.com/north-korea-internet-behavior/.
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[15] Timothy Martin, “New North Korea Hack: Hijacking Computers to Power Cryptocurrency Mining,” Wall Street Journal, January 8, 2018, https://www.wsj.com/articles/in-north-korea-hackers-mine-cryptocurrency-abroad-1515420004.
[16] Kim Yoo-chul, “Cryptocurrency – A New Revenue Source for North Korea?,” Korea Times, August 31, 2018, http://www.koreatimes.co.kr/www/nation/2018/08/113_254646.html.
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[19] Priscilla Moriuchi, “Asia Transnational Threats Forum: Cybersecurity in Asia,” June 14, 2018, Brookings Institution video, 45:00, https://www.brookings.edu/events/asia-transnational-threats-forum-cybersecurity-in-asia/.
[20] “Survey of Bitcoin Mixing Services: Tracing Anonymous Bitcoins,” Novetta, September 2015, http://www.novetta.com/wp-content/uploads/2015/10/NovettaBiometrics_BitcoinCryptocurrency_WP-W_9182015.pdf.
[21] Priscilla Moriuchi, “Asia Transnational Threats Forum: Cybersecurity in Asia,” June 14, 2018, Brookings Institution video, 46:32, https://www.brookings.edu/events/asia-transnational-threats-forum-cybersecurity-in-asia/.
[22] Ali Raza, “Monero – Privacy and Anonymity on the Blockchain,” Cryptoslate, February 10, 2018, https://cryptoslate.com/monero-privacy-anonymity-blockchain/.
[23] Ali Raza, “Monero – Privacy and Anonymity on the Blockchain,” Cryptoslate, February 10, 2018, https://cryptoslate.com/monero-privacy-anonymity-blockchain/.
[24] Cynthia Kim and Joyce Lee, “South Korea’s Bithumb Loses $32 Million in Digital Money Heist, Bitcoin Falls,” Reuters, June 19, 2018, https://www.reuters.com/article/us-crypto-currencies-southkorea/south-koreas-bithumb-loses-32-million-in-digital-money-heist-bitcoin-falls-idUSKBN1JG07F; all monetary values represent the value at the time of publication and have not been adjusted to account for nominal exchange rates between foreign currencies.
[25] “South Korean Cryptocurrency Exchange to File for Bankruptcy After Hacking,” Reuters, December 19, 2017, https://www.reuters.com/article/us-bitcoin-exchange-southkorea/south-korean-cryptocurrency-exchange-to-file-for-bankruptcy-after-hacking-idUSKBN1ED0NJ.
[26] Laignee Barron, “North Korean Hackers may have Stolen $530 million from a Japanese Cryptocurrency Exchange,” Fortune, February 6, 2018, http://fortune.com/2018/02/06/north-korea-coincheck-hack/.
[27] Priscilla Moriuchi, “Asia Transnational Threats Forum: Cybersecurity in Asia,” June 14, 2018, Brookings Institution video, 54:20, https://www.brookings.edu/events/asia-transnational-threats-forum-cybersecurity-in-asia/.
[28] Cynthia Kim and Joyce Lee, “South Korea’s Bithumb Loses $32 Million in Digital Money Heist, Bitcoin Falls,” Reuters, June 19, 2018, https://www.reuters.com/article/us-crypto-currencies-southkorea/south-koreas-bithumb-loses-32-million-in-digital-money-heist-bitcoin-falls-idUSKBN1JG07F.
[29] “A Snapshot of Current Crypto Regulations of All G20 Member States,” Torque Ventures, March 14, 2018, https://www.google.com/url?q=https://www.globallegalinsights.com/practice-areas/blockchain-laws-and-regulations/china&sa=D&ust=1592856263093000&usg=AFQjCNHvkETPvX0r3KnZRgHJC0N9lwBZUg.
[30] “A Snapshot of Current Crypto Regulations of All G20 Member States,” Torque Ventures, March 14, 2018, https://medium.com/torque-capital-partners/a-snapshot-of-current-crypto-regulations-of-all-g20-member-states-3b5f80ffac81; Chrisjan Pauw, “South Korea and Crypto Regulations, Explained,” CoinTelegraph, February 6, 2018, https://cointelegraph.com/explained/south-korea-and-crypto-regulations-explained.
[31] Chrisjan Pauw, “South Korea and Crypto Regulations, Explained,” CoinTelegraph, February 6, 2018, https://cointelegraph.com/explained/south-korea-and-crypto-regulations-explained.
[32] Cynthia Kim and Heekyong Yang, “Uproar Over Crackdown on Cryptocurrencies Divides South Korea,” Reuters, January 12, 2018, https://uk.reuters.com/article/us-southkorea-bitcoin/uproar-over-crackdown-on-cryptocurrencies-divides-south-korea-idUKKBN1F10YG.
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[34] “(LEAD) Gov’t to require real-name transactions in cryptocurrency trading,” Yonhap, December 28, 2017, https://en.yna.co.kr/view/AEN20171228005651315.
[35] “(LEAD) Gov’t to require real-name transactions in cryptocurrency trading,” Yonhap, December 28, 2017, https://en.yna.co.kr/view/AEN20171228005651315.
[36] Chrisjan Pauw, “South Korea and Crypto Regulations, Explained,” CoinTelegraph, February 6, 2018, https://cointelegraph.com/explained/south-korea-and-crypto-regulations-explained.
[37] Chrisjan Pauw, “South Korea and Crypto Regulations, Explained,” CoinTelegraph, February 6, 2018, https://cointelegraph.com/explained/south-korea-and-crypto-regulations-explained.
[38] Kevin Helms, “South Korea to Follow G20 Unified Cryptocurrency Regulations,” Bitcoin News, May 17, 2018, https://news.bitcoin.com/south-korea-g20s-unified-cryptocurrency-regulations/.
[39] “South Korea to Ease Cryptocurrency Trading Regulations, Highly Optimistic,” News BTC, May 7, 2018, https://www.newsbtc.com/2018/05/07/south-korea-ease-cryptocurrency-trading-regulation-highly-optimistic/.
[40] Julia Kollewe, “Bitcoin Prices Plunges after Cryptocurrency Exchange Hack,” Guardian, June 11, 2018, https://www.theguardian.com/technology/2018/jun/11/bitcoin-price-cryptocurrency-hacked-south-korea-coincheck.
[41] Julia Kollewe, “Bitcoin Prices Plunges after Cryptocurrency Exchange Hack,” Guardian, June 11, 2018, https://www.theguardian.com/technology/2018/jun/11/bitcoin-price-cryptocurrency-hacked-south-korea-coincheck.
[42] Stephen Obie and Mark Rasmussen, “How Regulation Could Help Cryptocurrencies Grow,” Harvard Business Review, July 17, 2018, https://hbr.org/2018/07/how-regulation-could-help-cryptocurrencies-grow.
[43] Stefan Stankovic, “US Cryptocurrency Regulation: Policies, Regimes & More,” Unblock, updated February 18, 2019, https://unblock.net/us-cryptocurrency-regulation/.
[44] Bill DeLisle, “The Current State of Cryptocurrency Taxes in the U.S.,” Cryptoslate, March 19, 2018, https://cryptoslate.com/us-cryptocurrency-taxes/.
[45] Drew Maloney, Assistant Secretary for Legislative Affairs, Department of Treasury, letter to Senator Ron Wyden, Coin Center, February 13, 2018, https://coincenter.org/files/2018-03/fincen-ico-letter-march-2018-coin-center.pdf.
[46] Stephen Obie and Mark Rasmussen, “How Regulation Could Help Cryptocurrencies Grow,” Harvard Business Review, July 17, 2018, https://hbr.org/2018/07/how-regulation-could-help-cryptocurrencies-grow.
[47] Stephen Obie and Mark Rasmussen, “How Regulation Could Help Cryptocurrencies Grow,” Harvard Business Review, July 17, 2018, https://hbr.org/2018/07/how-regulation-could-help-cryptocurrencies-grow.
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