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        est business. When processors accept
        large volumes of high-risk process-
        ing without reserves or provide cash         Think of the roulette wheel turning
        advance without a claim on future          already and investors being invited to
        receivables, money can quickly dis-
        appear.                                   place their bets or be left out altogether.

        As I have written in this column
        many times over the years, a contract
        is  not  much  better  than  the  parties   Conclusion
        signing it. In FTX it appears that the   The great thing about law is that it has studied fraud for centuries. The question
        counter-parties of its investors—and
        customers—were not trustworthy.       for investors is whether they want to use legal tools—such as due diligence,
                                              liens, audit rights and legal opinions to protect themselves—or, instead, make
                                              big blind bets hoping for a fast buck.
        Traditional deal  makers  might  have
        asked for a face-to-face meeting with
        SBF to assess his trustworthiness.    For  the record,  none of the crypto platforms  mentioned  in  this  article  took
                                              legal advice from our firm (www.bitcoin.law) nor did investors that were also
        Perhaps, the rush to invest, and a
        preference for Zoom over IRL caused   mentioned herein.
        investors to side-step those meetings.
        Would other investors in the same     In publishing The Green Sheet, neither the author nor the publisher is engaged in rendering legal,
        spot make the same decision? Who      accounting or other professional services. If legal advice or other expert assistance is required,
        knows? We can only speculate.         the services of a competent professional should be sought. For further information on this article,
        Not your keys, not your coin          please contact Adam Atlas, attorney at law via email at atlas@adamatlas.com or by phone at
                                              514-842-0886.
        Die-hard Bitcoin and other crypto
        fans believe that if a user does not
        exclusively control their private
        keys, then they do not actually own
        the coin in the wallets that use those
        keys. Private keys are the codes nec-
        essary to initiate outbound transac-
        tions from a crypto wallet.

        Hosted crypto wallet providers, like
        FTX, Binance, Coinbase and others
        hold onto those keys on behalf of
        their users. Unhosted crypto wal-
        let solutions, like Ledger and Tezor,
        make it easy for users to control their
        own private keys.

        Every crypto implosion has been on a
        platform where user keys and assets
        are held by a centralized exchange,
        like FTX. The maxim "Not your keys,
        not your coin" rings truer than ever
        now. The problem with just holding
        your crypto in an unhosted wallet is
        that you cannot also gamble with it at
        the same time.

        This tension between the security of
        holding  digital  assets  versus  the  ir-
        resistible allure of gambling them for
        potentially great returns is likely here
        to stay.



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