Interesting project, I read the whitepaper but I have some questions (which to my surprise haven’t been asked already);
1. 2.3 Identity Verification: The Digital Identity Trust Network (DTN)
DTN appears to be a separate entity to the NAC foundation and processes the verification of users (through government issued documents and biometric means) needed to get access to the AML blockchain.
Could you please elaborate about this; how can I trust DTN? Is there any regulatory oversight on this company? Is it being audited? Do they store all the ID data on their own servers and on the NAC servers (and how do they communicate)? And how are the costs of verifying AML users being covered?
2.3.2 Explains how users can identify; 'they select their Country of residence, and State or Province'.
How do I know my country is on that list? If not I cannot convert AML Token to AML Bitcoin.
2. 3.6.4 Locking the AML BitCoin Accounts of Suspected Criminals
Reading this part, it seems to enter quite a grey area, with has 2 downsides;
I. there seems to be a lot of non-automated work associated with it, do you plan on having a whole team on this? And how do you plan on covering the ongoing costs associated with it?
II. If NAC may deem something suspicious, can they lock my funds? Or is it only 'Upon a legitimate request from a governmental body'?
P.S. I'm not talking about 3.5 (because I understand being on some terrorist list, NAC will lock the account but that is no grey area).
3. 6.2 Limitations of Bitcoin and Other Cryptocurrencies
In this part you cover 3 subjects of limitations (on which I agree), but on only one (6.2.3. Pseudonymous/Anonymous Property of Cryptocurrency and Illegal Activities) seems AML bitcoin to serve a solution, do I read that right?
4. Although not in the whitepaper, but it was stated (in the FAQ I believe) that all the centralized (ID) information is not stored on front-end servers of NAC, which is nice, but is of course not a guarantee for anything.
How do I know this information is really stored securely, not only in a technical sense, but also in procedural form (which employees have access under what conditions, etc.); are you audited by an external company?
5. Having 50 million of AML bitcoin to burn trough will ensure NAC not going broke soon, but how are you planning long term to fund yourself?
6. Because every AML Bitcoin is stored in multi sign addresses (me and NAC having the keys), it is absolutley vital NAC will keep functioning, what provisions are made to that end? Things like disagreements/infighting (everybody leaving NAC) or the whole NAC team is involved in a plane crash or something..
Let me try to address your concerns briefly here. Otherwise, it will be an extremely lengthy post.
1. 2.3 Identity Verification: The Digital Identity Trust Network (DTN)
DTN appears to be a separate entity to the NAC foundation and processes the verification of users (through government issued documents and biometric means) needed to get access to the AML blockchain.
Could you please elaborate about this; how can I trust DTN? Is there any regulatory oversight on this company? Is it being audited? Do they store all the ID data on their own servers and on the NAC servers (and how do they communicate)? And how are the costs of verifying AML users being covered?
Brief Answer: The DTN involves a third-part company, who has experience and expertise to verify the submitted identity proof document. The third-party company’s method should have been audited. Most data are stored on the NAC servers (not front-end servers). All personal information is encrypted before storage in our servers. Some data will be stored using the IPFS protocol. For communication between Internet interfaces for ID data submission and the 3rd-party ID verification platform, network traffic encryption will be involved. We will follow the ISO/IEC 29100:2011 standards (Information technology - Security techniques - Privacy framework), and the system will be subjected to third-party accreditation. Some of the costs of verifying AML users are from the ICO. Some of the costs are covered by the profits from our business. Please refer to the white paper for the basic ideas about our business plan.2.3.2 Explains how users can identify; 'they select their Country of residence, and State or Province'.
How do I know my country is on that list? If not I cannot convert AML Token to AML Bitcoin.
Brief Answer: (1) If you are a resident/citizen in a country in the OFAC sanctioned country list, you cannot convert AML Tokens to AML BitCoins. (2) If you are staying in a country in the OFAC sanctioned country list, you cannot convert AML Tokens to AML BitCoins. Please refer to our Terms and Conditions for more details. https://amltoken.com/aml-sale-terms-and-conditions/2. 3.6.4 Locking the AML BitCoin Accounts of Suspected Criminals
Reading this part, it seems to enter quite a grey area, with has 2 downsides;
I. there seems to be a lot of non-automated work associated with it, do you plan on having a whole team on this? And how do you plan on covering the ongoing costs associated with it?
Brief Answer: This is a very good question. We have thought of a solution on covering the ongoing costs associated with it. Unfortunately, owing to the trade secret, I could not disclose detailed information to you here. I hope you could understand. However, you can think in way that NAC Foundation will develop its business to generate profits, and the ongoing costs will be covered by the profits of our business. You could refer to our whitepaper for the basic ideas of our business plan. II. If NAC may deem something suspicious, can they lock my funds? Or is it only 'Upon a legitimate request from a governmental body'?
P.S. I'm not talking about 3.5 (because I understand being on some terrorist list, NAC will lock the account but that is no grey area).
Brief Answer: For suspicious transactions, we are not planning to lock those funds. However, we are planning to report those suspicious activities to the related government agencies, e.g. FinCEN in United States. We will only lock those funds upon a legitimate request from a governmental body. 3. 6.2 Limitations of Bitcoin and Other Cryptocurrencies
In this part you cover 3 subjects of limitations (on which I agree), but on only one (6.2.3. Pseudonymous/Anonymous Property of Cryptocurrency and Illegal Activities) seems AML bitcoin to serve a solution, do I read that right?
Brief Answer: I hope that I understand your question correctly. If not, please correct me. AML BitCoin is designed to serve as a solution for the illegal activities related to the pseudonymous/anonymous property of cryptocurrency. 4. Although not in the whitepaper, but it was stated (in the FAQ I believe) that all the centralized (ID) information is not stored on front-end servers of NAC, which is nice, but is of course not a guarantee for anything.
How do I know this information is really stored securely, not only in a technical sense, but also in procedural form (which employees have access under what conditions, etc.); are you audited by an external company?
Brief Answer: Correct. Centralized (ID) information will not be stored on front-end servers of NAC. We will follow the ISO/IEC 29100:2011 standards (Information technology - Security techniques - Privacy framework), and the system will be subjected to third-party accreditation. 5. Having 50 million of AML bitcoin to burn trough will ensure NAC not going broke soon, but how are you planning long term to fund yourself?
Brief answer: We are well aware of the need of long term fund to keep the AML BitCoin running. Please refer to whitepaper for the basic ideas of our business plan. AML BitCoin’s operation will be supported by the profits generated from our business. 6. Because every AML Bitcoin is stored in multi sign addresses (me and NAC having the keys), it is absolutley vital NAC will keep functioning, what provisions are made to that end? Things like disagreements/infighting (everybody leaving NAC) or the whole NAC team is involved in a plane crash or something..
Brief answer: The key answer for your question is the “provision”, that NAC is going to make at the end. We have a plan to build one or more valuable assets as the provision to ensure there will be sufficient fund that supports the continuous operation of the AML BitCoin system. As such information is trade-secret, I could not disclose in details here. Moreover, here we have to emphasize that the market price of the AML BitCoin must not be linked to those provisions, and AML BitCoin holders should not expect that the acquisition of AML BitCoin will result in profit because of those provisions. The price of AML BitCoin should be mainly dictated by the market force. This is to ensure that AML BitCoin is not considered as a security.