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Proposal: Dash ATM Master Compliance Program - Phase I

Discussion in 'Pre + Budget Proposal Discussions' started by Ryan Taylor, Aug 21, 2016.

  1. Ryan Taylor

    Ryan Taylor Well-known Member
    Dash Core Team Foundation Member

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    This is a cross-post from www.dashcentral.org/p/bsdev-ATMCompliance1

    As we have recently completed the development of Dash-compatible ATM software, we have been working hard on the next steps to a strategy to develop a large decentralized network of Dash Terminals (ATMs) that interface cash with the Dash network. We are calling them "terminals" to make a distinction as we expect them in the future to do more than just converting cash with Dash or Bitcoin. Most importantly, we are looking to do this in a way that can be decentralized and promote inclusion of small and independent operators.

    What are the main barriers for independent crypto ATM operators entering the industry?

    Independent operators desiring to run digital currency ATMs currently face one main obstacle; there is a great deal of legal and compliance hurdles to overcome, and they typically must address different regulations in each of the jurisdictions in which they operate. For example, in the United States, the definition of money transmitters and the regulations with which operators must comply varies by state.

    Needless to say, this regulatory burden is significant, especially for the small operators that would like to run one or two machines. Many people just shy away from dealing with the regulatory issues as is prohibitively costly for small operations. This results in only larger, more formal and centralized companies being able to run machines and offer a cash entry into the crypto economy. The cost to maintain compliance is among the largest costs of any ATM operator, and this is one of the reasons digital currency ATMs must charge high fees (which average 6.85%). High fees in turn limit usage, which leads to fewer locations, reduced access, and a loss of convenience for consumers.

    We believe that a compliance program designed to share the compliance burden across operators would add tremendous value to the operators themselves and at the same time benefit consumers through the evolution of lower fees and more locations over time. We also believe the only reason why something like this does not exist already is because Dash is the only blockchain that has the ability to create this sort of public infrastructure that can benefit everyone on the network.

    How can Dash help, and what are the benefits?


    We propose to create a global affiliate compliance program in which operators purchase and operate their own machines, and pay a portion of their fees to participate in the program. This would be similar to an affiliate program like Uber in which the operators would own their own businesses, but pay a portion of their fees for the benefits of participating in the affiliate program.

    The Dash network would fund the initial program setup. Once established, the network would benefit in several ways:
    1. In order to participate, operators would be required to operate the official compliant version of ATM software, which would include support for Dash; this would encourage existing and new operators to add Dash support and allow us to capture a share of new operators entering the space
    2. Fees collected from ATM operators would be used to pay for the ongoing costs of maintaining the compliance program, and any profits would be returned to the network, or potentially allocated towards further investment in the program if the masternodes support it (e.g., expanding the program to new jurisdictions)
    3. We would become the first digital currency project to derive a revenue stream besides network fees and inflation, paving the way for the industry once again by creating a new paradigm for sustainability and relevance
    4. We believe this program will send a signal to potential Dash investors of higher future returns from operating a masternode, and increase the value of Dash accordingly
    5. Dash will have the unique position of controlling the software on the machines, meaning we will be able to deploy new Dash-specific features to the Terminal network at our discretion; this could include direct connections through to Evolution when it is deployed or rolling out additional services (e.g., partnerships for pre-paid phone top-ups, event ticket sales, etc)
    How would such a program be created?

    After much discussion and planning, we propose rolling out the program in phases. This will allow us to minimize upfront costs, incorporate findings from each phase of work toward planning the next, and enable us to eliminate funding if early results are poor.

    We believe the value of a master compliance program would be greatest in the United States, where the potential market is large and compliance costs are the most significant for ATM operators. For this reason, we believe the United States would be the best place to start the program, as operators in the US would see the most to gain from participating.

    The first phase would consist of the following:
    • Establish the Principal Compliance program (the compliance program of a legal entity running the service)
    • Establish the Agent Compliance program (the compliance program the affiliate ATM operators would need to implement)
    • Create Operator Agreement documents to establish the Agent / Principal relationship
    • Banking packages which would allow operators to apply for bank accounts in an orderly fashion while meeting all bank documentation requirements
    • Creation of a compliance education and training program for the agents
    • Assessment of risks and potential mitigation steps
    • Planning for Phase II of the program
    Once the legal frameworks, agreements, and training programs are established, Phase II will be to run a small scale pilot (of ~20 machines), to gather real-world data on usage and revenue generation, and to test and refine the compliance program. The pilot program would take place within a small number of states, but would be open to a limited number of community members living in those states. The deliverables at the end of Phase II would include published results from the pilot (e.g., usage, revenue, maintenance costs, cash handling costs, hours spent on compliance reporting, etc.).

    Phase III of the program would establish additional states within the program and scale the program. It would also include marketing the services to existing operators, and onboarding them.

    What are the details for Phase I?

    We have been consulting with a law firm out of D.C., called Cogent Law Group, LLC regarding this potential program. We started talking to them while in San Francisco during the d10e conference and are impressed with their depth of experience in the crypto KYC / AML space. They are among a handful of firms with customers running an ATM network and have established digital gold programs. After many interactions with them since last month, we feel confident in their expertise and are confident recommending them for the work.

    Cogent Law Group also hosts a startup program called the Early-to-Mid-Stage Initiative (EMS Initiative) in which they provide discounted, deferred fee, capped fee, and even free legal consulting to entities accepted into the program. We are delighted that they have accepted our application to the program, and have benefitted immensely from their advice and research up to this point, all free of charge. They also have assisted us with smaller requests free of charge, such as providing NDAs.

    As part of our participation in the EMS Initiative, Cogent Law Group has agreed to conduct Phase I of the program at a discount and subject to a fee cap. This proposal would fund Phase I by providing a $10,000 retainer, which would represent the maximum fees for creating the materials already described for Phase I. Any residual funds can be deployed toward Phase II.

    Included in this fee, we will also establish processes with a third-party compliance officer recommended by Cogent. A third party compliance officer is a requirement for the program. BitAML – the recommended partner – is a firm that specializes in Bitcoin compliance, Bitcoin AML, and Bitcoin ATM Regulation.

    Further, volunteer operators when we get to Phase II that want to order hardware directly from Lamassu may do so. We would coordinate the ordering of the machines, which will be flashed with the Dash software stack so machines will be fully compliant with the program as shipped from the the factory floor, without the need for modification. We will also explore other hardware options when the time comes.

    How long will the program take to create?

    Once funded, it should take approximately 3-4 weeks to create all the legal, training, and banking packages required. We will also receive a more detailed plan for Phase II.

    How much will this cost in total across all three phases?

    The costs beyond Phase I are dependent on the research which will be conducted as part of the work. Because a master compliance program has never been set up before, and the exact functioning of the program will depend on feedback and guidance the states provide us on their requirements, it is impossible to know with certainty the costs of running a sub-scale Phase II pilot. Informally, we expect Phase II will cost no more than $30,000 to conduct, including the services from BitAML. Please remember even at the pilot stage the machines are an income generating service.

    How much fees could this program generate?

    A typical digital currency ATM volume really varies a lot and depends on the location some can do $100K/month some can do $10K/month, examples of profitability can be found here. In reality we feel that the high fees make a lot of people not use them. If we can offer more competitive fees by decentralizing operations and sharing costs they can become a better alternative to easily buy coins like Dash and Bitcoin. If we take a 1% share of transaction fees for the network depending on volume direct return to the network could be substantial and still leave space for operators to make good returns and be competitive. We will get a more concrete idea of the revenue and profit potential after Phase II is complete.

    Summary:

    We view this compliance program as a critical first step in researching the expansion of our ecosystem, both in terms of facilitating greater fiat access for users, and in terms of generating new income sources for the network. Additionally, by making it easier for ATM operators to address compliance issues at a lower cost, we can accelerate the deployment of Dash ATMs without the need to directly subsidize machine purchases. The investment is modest and well within the capacity of the network. It also creates a new investment option for community members looking to help the Dash network to expand. Lastly, it will allow us to deploy new ATM-based services faster than any competing networks, and to offer a consistent user experience across the machines of a distributed set of operators.

    We look forward to your questions and comments.

    Requested funding is as follows for the September 4th budget cycle:
    Total: 748.99 Dash

    Note: Any unused budget will be applied toward other business development expenses

    Manually vote YES on this proposal:
    dash-cli mnbudget vote-many 41c6f95adf836b2a517510d1141c00024dbc5c5db7abbb39c123e631397975f8 yes
    OR from the qt console:
    mnbudget vote-many 41c6f95adf836b2a517510d1141c00024dbc5c5db7abbb39c123e631397975f8 yes

    Manually vote NO on this proposal:
    dash-cli mnbudget vote-many 41c6f95adf836b2a517510d1141c00024dbc5c5db7abbb39c123e631397975f8 no
    OR from the qt console:
    mnbudget vote-many 41c6f95adf836b2a517510d1141c00024dbc5c5db7abbb39c123e631397975f8 no
     
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  2. Dash Advocate

    Dash Advocate New Member

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    Does this compliance program mean that the compliance risks of each ATM operator are shifted to Dash? If so - that would mean there will be a single point of failure for Dash, that a government could easily exploit. Just sue all the ATM owners, and Dash is dead. Basically, a "Master Compliance Program" by definition is a centralizing effort. Especially when you have something like this; "Dash will have the unique position of controlling the software on the machines".

    I hope I have this wrong. Please clarify that Dash will NOT be accepting any additional risk by doing this.
     
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  3. TanteStefana

    TanteStefana Moderator
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    Good question, Dash Advocate!

    Also, I would like to know where the generated fees would go? How will they be held and allocated? I would think they would go toward maintenance of the licensing, but after that, what happens?

    I would also want a clear commitment that everything learned is divulged to voters / community. So that questions like Dash Advocate's are answered and backed up with data. Even if it's case law and can't otherwise be guaranteed.

    If we do something like this, I would say it's time to have a law firm on retention as well as lobbyists. We'll need to protect ourselves.

    I know I'm paranoid, but you can't trust which way the law will see you. It can go any which way. But this proposal is to find out if this can work, and I think it's well worth looking into :)
     
  4. camosoul

    camosoul Well-known Member

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    Why do you care about ATMs when you could skip that whole mess and just set up vendors to accept crypto in a simple way that mirrors the POS process and compliance system they're already doing?

    No legal compliance issues because they're already doing it... Nothing to learn,. a familiar interface that they're already using... Retail adoption could be easier than falling down. Skip the ATM silliness.

    Why does DASH/IX exist if those features are going to be ignored in favor of a convoluted/complex band-aid for a shortcoming that DASH doesn't have?

    The Community and the "Business Devs" who have absolutely zero experience in any business at all, continue to cling to familiar crypto paths in the name of hype/pump, instead of blazing the simple, short, obvious trail that bypasses all this BS... So timid and afraid of change... The very change DASH was meant to cause...

    This is the most obvious pork/money pit of all time. But, the rats will follow the pied pipers right off the cliff... Even if you succeed in this; so what? I could set the world record for sticking pine cones up my ass. What would be accomplished? This is every bit as silly... It's just a huge, complex, expensive, needless, pointless distraction from the simple, easy, direct, cheap thing that could be done instead, and might actually be useful...
     
    #4 camosoul, Aug 21, 2016
    Last edited: Aug 21, 2016
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  5. Minotaur

    Minotaur Well-known Member
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    Hi Dash Advocate, no it does not mean that the risk is spread. Each independent operator would be a separate entity completely independent from each other and liability is limited to each independent operator.

    Also Dash is a blockchain not the entity running any program so no there is no exposure from the network at all. About the software what we mean is operators have an incentive to run the same software to participate on the program, not an obligation.

    Thanks for the questions, our plan is to gather questions and feedback and do a podcast with the lawyers and compliance experts that will be helping create it to explain further.
     
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  6. Minotaur

    Minotaur Well-known Member
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    We understand your point very well, rather than FIAT interfaces you favor direct adoption by people that dont want to use FIAT anymore just adopt Dash. I agree that is a worthwhile goal that should be pursued but I think is not exclusive to creating a network of terminals that could interface into Evolution. Feel free to promote direct adoption of POS, I think there are people working on that like Blockpay that supports Dash. One thing does not prevent the other.
     
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  7. camosoul

    camosoul Well-known Member

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    No, but one does render the other vestigial.
     
  8. camosoul

    camosoul Well-known Member

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    No. You're missing the point entirely.

    Why generate another massive mess/layer of compliance needs? Who's going to do that for free? You're generating another complex point of failure where none need be. another layer of fees, because this mess will have to be incentivized.

    Maybe the Vendors aren't the slightest bit interested in "adopting" DASH. Who cares? You're missing the point. They don't have to know a damn thing about DASH, or care one whit about "adopting" it.

    Who needs a "terminal" when they already have a smartphone? It's the same thing as having a computer in your car. It's pointless and stupid. You already have one in your pocket that goes everywhere...

    The only reason there is a perceived "need" for this ATM stuff, is because of the seemingly willful failure (refusal) to do the cheap, simple route that doesn't require any of this crap. It's already been a year of soaking up money for no useful purpose, when you could get to the point with something truly useful in about 4 days...

    You go out of your way to subvert any effort that isn't handed down from The King. The only time y ou and your buddies show up in other projects, is to troll and spread mis-information in the form of off-the-wall questions, pretending to be concerned. Evan did it himself...

    I understand what you're doing. I just can't find a reason why it needs to be done... There are better things that would cost a fraction and could be done by the middle of next week.

    The desperate need to spite an idea just because @camosoul had it, is painfully immature.

    It's like words can't even be seen or heard unless they're about the ponzi/hype/pump...
     
    #8 camosoul, Aug 21, 2016
    Last edited: Aug 21, 2016
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  9. camosoul

    camosoul Well-known Member

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    It's like you're trying to design the next AOL when you could easily just, you know, not... Does anyone really need this? How will this enable anyone to spend their crypto? More fees. More red tape... All in the name of accomplishing a do-nothing project that serve no useful purpose?

    I could work really hard at designing a farm on the surface of the Sun. I could probably waste a lot of money comping up with ways to solve that "problem." But, what good would it do? Who needs to build a farm on the Sun?
     
    #9 camosoul, Aug 21, 2016
    Last edited: Aug 21, 2016
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  10. Dash Advocate

    Dash Advocate New Member

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    I agree with Camosoul. I'm not sure I even agree with the idea of a DASH ATM network at all. I mean - if I can buy/sell DASH for cash with zero KYC steps, then I would be interested. But, this proposal is all about satisfying KYC/AML etc. There already is a network for that .... mobile access to currently operating exchanges. So, can someone point out where I have this 'high-level' view wrong? Even if this plan is executed perfectly, (and I really doubt it will be based on the Scamassu project) it buys us nothing but a few press releases. There are much better ways to spend the DGBB budgets.
     
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  11. Dash Advocate

    Dash Advocate New Member

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    "Also Dash is a blockchain not the entity running any program so no there is no exposure from the network at all. "

    Not sure what you are trying to say there, but the Dash blockchain is not what is going to tell the the ATM owners they are compliant. It is someone at the Dash organization.

    " .... liability is limited to each independent operator."

    Great! So when they all get sued by the government, and the Dash organization told them they were compliant, how is it that the Dash organization is not liable?

    Maybe get the ATM owners to sign something that says;

    Hey - we know we told you that you don't need to get your own legal counsel if you are approved by our compliance program, but you can't sue us if we are wrong."
     
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  12. halso

    halso Active Member

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    ATMs are a great idea. You have my votes.
     
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  13. alex-ru

    alex-ru Grizzled Member
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    Have we already made a research about "market demand" for "Phase II"?
    I mean: do we already have these "limited number of community members" who are ready to buy (themselves) these 20 ATMs and waiting for the result of "Phase I"?

    In other words: Before spending 10.000 USD on "Phase I - Documentation" - we must be sure that we have potential customers for "Phase II - Buying ATMs"
    And we must be sure: do they really need this "Documentation"? Or maybe they would prefer other kinds of help with establishing DASH ATM's Network?

    Thanks.
     
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  14. Dash Advocate

    Dash Advocate New Member

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    Alex-Ru - you make very good points. The fact that we are able to quickly poke holes in proposals is extremely telling. It means no one is thinking things through. They are just trying to spend the budget. Letting money disappear from the 'table' is typically a bad business move, but it is far more important that we go the right direction slowly, than to go the wrong direction fast. There seems to be no sanity checks to filter out such mistakes. What this tells me, is that we need someone else driving the Dash team. Maybe that is where the money is better spent!
     
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  15. stan.distortion

    stan.distortion Active Member

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    ATMs, points of sale, debit cards, vending machines, payment widgets, tipbots, toll passes, lottery tickets, etc, etc, etc... There's no either/or but Camo gets going and things can look that way :/ Everywhere value changes hands. Everywhere, even the most trivial economic backwater is relevant. Personally I couldn't give a rats ass about compliance but it's important to an awful lot of people for using Dash to move value and therefore it's worthwhile.
     
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  16. Dash Advocate

    Dash Advocate New Member

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    But this compliance proposal basically say to ATM owners; "You don't need legal counsel if you follow this Compliance Program, but we can't be certain, so you are responsible and you better get legal counsel." Complete waste of money.
     
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  17. Macrochip

    Macrochip Active Member
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    We are still clinging to the financial establishment by trying to shove a technology into it, that was meant to free us from legal hinderances such as KYC and AML.

    The old system has put us into financial chains and we are given the instruments of our liberation (cryptocurrency).

    Yet here we are trying to put the chains back on, because they're more comfortable than rising up and making our own way.

    It's a true tragedy to see this play out. To see us even pay for our own re-enslavement.
     
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  18. halso

    halso Active Member

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    We need FIAT gateways to grow, and that will require a level of compliance.

    Once you have your crypto, thats where the compliance stops. You are free to use it as u please in private.

    I understand the philosophical objections, but we need to be pragmatic. We need to take some risks and try things out.

    @babygiraffe are u thinking BTC & Dash, or just Dash with these ATMs?
     
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  19. TheDashGuy

    TheDashGuy Well-known Member

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    Keep letting them completely waste the budget on things like this, and when the entire project collapses, I'm going to laugh my ass off and short the shit out of it when the time comes because this house of cards is already built on shaky foundations and having Daniel in charge gets you nothing but AML/KYC integration with Dash. LOLOL!

    @eduffield grow a spine and take back your project. You are honestly pissing me off at this point, my pity obviously doesn't matter so maybe my attacks and trolling will. Get your shit together and stop letting the guy who would literally sell you out to the government overnight run the show.

    And to the rest of you, get a fucking voice please, at this point you are FAR worse than meer sheeps. You are accomplices.


    Stop funding scams please, it's bad for business. : https://dashcentral.org/p/lamassu-integration
     
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  20. stan.distortion

    stan.distortion Active Member

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    "Complete" is a binary and this is anything but, it's potentially an endless task to cover every region or set of regulations and that's the bit that worries me most, all this stuff is potentially a budgetary black hole. Covering it stage by stage is worthwhile imho, get somewhere like Berlin with a large crypto awareness covered and it could do a huge amount for adoption and pave the way for all of Europe. Maintanence costs are a concern though, a lot of this crap is aimed at "boosting the economy", ie. fecking expensive red tape that goes on being expensive year after year, imho phase 1 is working out the initial and ongoing costs and phase 2 is paying the most cost effective of them.
     
  21. halso

    halso Active Member

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    Gents,

    lets keep the conversion civil. We can all make our points without the hostility.

    Ultimately we have a voting mechanism that will resolve any differences.

    No need for the personal attacks.
     
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  22. Ryan Taylor

    Ryan Taylor Well-known Member
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    BTC and Dash. BTC will initially be where all of the volume would come from. Lacking BTC support - with or without a compliance program - is a non-starter for any operator and we would see no adoption of the program. The idea is to co-opt existing operators and entice any new ATM deployments that would otherwise only offer BTC into offering both BTC and DASH.

    Offering BTC is also good for Dash... you will have customers that are there to buy BTC - customers who are not only familiar with cryptocurrency, but are actually using it - being exposed to Dash each time they transact. Every time they use the ATM, they will get another exposure to Dash, and many will seek to learn about it. We believe this would be more effective at expanding our market than Dash-only machines.
     
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  23. Miner237

    Miner237 Well-known Member
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  24. Dash Advocate

    Dash Advocate New Member

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    Phase 1 just does documentation. Specific states are targeted in Phase 2. Frankly, I think this is backwards. There is nothing stopping us from picking 20 ATM owners right now - before we spend a single Duff on Phase 1. We may find there simply is no market demand.
     
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  25. kot

    kot Well-known Member
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    No offence @TheDashGuy but I can see these kind of "prophetic" statements since at least the beginning of the year. And what the facts say:
    chart.png

    I think it is definitely time to change this narration.
     
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  26. halso

    halso Active Member

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    Good strategy. So what incentive would there be for an existing operator to buy a new machine if he already owns one?
     
  27. Vedran Yoweri

    Vedran Yoweri Active Member

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    Keeping the software up2date.
     
  28. stan.distortion

    stan.distortion Active Member

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    Is that states as in nations around the world or states as in the United States?
     
  29. Ryan Taylor

    Ryan Taylor Well-known Member
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    Part of Phase I will be to investigate which states would make for ideal pilots. The law firm has pointed out that NY may be a particularly difficult state to meet compliance, so might be one of the most costly to implement something. So a place like NY would not be ideal for the pilot purposes.

    Our ingoing hypothesis is that Arizona should be one of the states, though, both because it should be a middle-level amount of regulation and because both Evan and I are located here and could run one or two pilot machines (which gives a couple of members of the core team personal experience with them and ability to better participate in testing). I personally would not want to own one normally, but am willing to buy one for the pilot and run it for a while.
     
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  30. Ryan Taylor

    Ryan Taylor Well-known Member
    Dash Core Team Foundation Member

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    It would allow existing Lamassau operators to convert their existing machines to our software stack. It would also provide an incentive for operators of other machine manufacturers to begin replacing their existing footprint with Lamassau / Dash ATMs and any new network expansion on the Lamassau machines (especially as they enter new states). Certainly not all operators, but some would see the value in migrating over time. I don't think they would be likely to rip out and replace existing non-Lamassau branded machines that are working just fine.
     

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