Intelligence Assessment

(U) Bitcoin Virtual Currency:Unique Features Present

Distinct Challenges for Deterring Illicit Activity

24 April 2012

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Prriminal Intelligence

Section

(U) A Bitcoin logo from https://en.bitcoin.it.

Assessment

(B) Executive Summary

(U//FOUO) Bitcoin – A decentralized,1 peer-to-peer (P2P) network-based virtual currency –

provides a venue for individuals to generate, transfer, launder, and steal illicit funds with some

anonymity. Bitcoin offers many of the same challenges associated with other virtual currencies,

such as WebMoney, and adds unique complexities for investigators because of its decentralized

nature.

(U//FOUO) The FBI assesses with medium confidence2 that, in the near term, cyber criminals

will treat Bitcoin as another payment option alongside more traditional and established virtual

currencies which they have little reason to abandon. This assessment is based on fluctuations in

the Bitcoin exchange rate in 2011 and limited reporting indicating bitcoins are being accepted as

payment by some cyber criminals.

(U//FOUO) The FBI assesses with low confidence, based on current user and vendor acceptance,

that malicious actors will exploit Bitcoin to launder money. This assessment is based on

observed criminal activities, investigations, and prosecutions of individuals exploiting other

virtual currencies, such as e-Gold and WebMoney. A lack of current reporting specific to

Bitcoin restricts the confidence level.

(U//FOUO) Even though there is no central Bitcoin server to compromise, the FBI assesses with

high confidence, based on reliable industry and FBI reporting, that criminals intending to steal

bitcoins can target and exploit third-party bitcoin services and an individual’s Bitcoin wallet.

Malicious actors can compromise personal computers and accounts using malware and hacking

techniques to steal users’ bitcoins and use botnets to generate bitcoins.

(U//FOUO) Bitcoin will likely continue to attract cyber criminals who view it as a means to

move or steal funds as well as a means of making donations to illicit groups. If Bitcoin stabilizes

and grows in popularity, it will become an increasingly useful tool for various illegal activities

beyond the cyber realm. Since Bitcoin does not have a centralized authority, law enforcement

faces difficulties detecting suspicious activity, identifying users, and obtaining transaction

records – problems that might attract malicious actors to Bitcoin. Bitcoin might also logically

attract money launderers and other criminals who avoid traditional financial systems by using the

Internet to conduct global monetary transfers.

(U//FOUO) Although Bitcoin does not have a centralized authority, the FBI assesses with

medium confidence that law enforcement can identify, or discover more information about

malicious actors if the actors convert their bitcoins into a fiat currency. Third-party bitcoin

services may require customers to submit valid identification or bank information to complete

transactions. Furthermore, any third-party service that qualifies as a money transmitter must

register as a money services business with the Financial Crimes Enforcement Network (FinCEN)

and implement an anti-money laundering program.

1 (U) See Appendix A for a glossary of terms. All terms included in the glossary are italicized on their first use.

2 (U) See Appendix B for a description of confidence levels.

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(U) Scope Note

(U//FOUO) The Cyber and Criminal Intelligence Sections, with contributions from the FBI

Detroit Division, initiated this intelligence assessment to explore the unique aspects of the P2P

virtual currency Bitcoin. This assessment does not attempt to judge the likelihood of Bitcoin’s

long-term success as an alternate payment method, but explores how bitcoins (or any future

virtual currency similar to Bitcoin) are traded and how criminals can use them to conduct illicit

activity. This assessment draws primarily on intelligence from January 2011 through April 2012,

unless otherwise referenced for historical perspective.

(U//FOUO) This is the FBI’s first Criminal and Cyber intelligence assessment related to Bitcoin.

In January 2012 the Counterterrorism Division disseminated an intelligence bulletin that

explored the potential to conduct illicit financial transactions using Bitcoin. Disseminated FBI

intelligence products on other virtual currencies include: (U) Cyber Criminal Exploitation of

Electronic Payment Systems and Virtual Currencies, dated 23 February 2011and (U) Cyber

Criminal Exploitation of Real-Money Trading, dated 8 June 2011, both of which discuss cyber

criminal misuse of virtual currencies for money laundering. While Bitcoin is a distinct virtual

currency, the overarching analytic judgments in this intelligence assessment about the use of

virtual currencies by criminal entities are consistent with these previous intelligence products.

(U//FOUO) This assessment will not address malicious actors outside of the cyber underground,

such as traditional organized crime groups, extremist groups, or child predators. Throughout the

paper, the term “Bitcoin,” when capitalized, refers to both the open source software used to

create the virtual currency and the P2P network formed as a result; “bitcoin” using lower case

refers to the virtual currency that is digitally traded between users.

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(U) Source Summary Statement

(U//FOUO) The FBI used open source reporting extensively in this intelligence assessment, both in support of

FBI reporting and to provide background information on Bitcoin. FBI sources vary from uncorroborated to highly

reliable. FBI case information citing criminal activity is considered highly reliable because it is from FBI

employees or FBI sources with direct access to the information.

(U//FOUO) Open source information comes from different online resources describing products or services

offered to conduct monetary transactions and are, therefore, considered reliable.

(U//FOUO) The FBI acknowledges that participants in the bitcoin economy have an incentive to emphasize the

popularity of Bitcoin. However, Bitcoin users also need reliable information about Bitcoin and the bitcoin

exchange rate. For the purposes of this assessment, the FBI assumes that the body of open source information

describing Bitcoin is generally indicative of the true state of the Bitcoin economy.

(U//FOUO) No contradictory information was found between FBI and open source reporting. Overall, the FBI

considers the body of reporting to be consistent and plausible in the context of the bitcoin environment.

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(U) The Bitcoin Economy

· (U) As of 18 April 2012, the third-party

bitcoin trading platform Mt. Gox recorded

more than $8 million in transactions

conducted over the past 30 days through Mt.

Gox trading, an average of more than

$276,000 per day.1

· (U) According to Bitcoin as of April 2012,

there were more than 8.8 million bitcoins in

circulation.2 With the average market price in

April 2012 between $4 and $5 per bitcoin, the

FBI estimates the Bitcoin economy was worth

$35 million to $44 million.3,4

· (U) From May 2011 Bitcoin values fluctuated

with exchange rates on Mt. Gox ranging as

high as $30 in June 2011 to a low as $4 in

December 2011.5

(U) Introduction

(U) Bitcoin3 is a decentralized, P2P network-based virtual currency that is traded online and

exchanged into US dollars or other currencies. Bitcoin, when paired with third-party services,

allows users to mine, buy, sell, or accept

bitcoins from anywhere in the world. Bitcoin’s

decentralized feature is unique among virtual

currencies. While Bitcoin developers4,6

maintain Web sites providing guidance to the

Bitcoin community, they do not have a

centralized database or authority. The P2P

network issues bitcoins through the mining

process and validates all transactions. Since

Bitcoin does not have a centralized authority,

detecting suspicious activity, identifying users,

and obtaining transaction records is

problematic for law enforcement.

(U) Despite the virtual nature of Bitcoin, users

value the currency for many of the same

reasons people trust Federal Reserve notes:

they believe they can exchange the currency for

goods, services, or a national currency at a later

date. As such, Bitcoin is currently accepted as a

form of payment at hundreds of legitimate retailers including vendors selling clothing, games,

music, and some hotels and restaurants.7 In addition, the unregulated nature of Bitcoin,

combined with its other unique features, attracts criminals to this form of payment and transfer

method.

(U) Unique Features Present Distinct Challenges for Detecting and Stopping Illicit Activity

(U//FOUO) FBI reporting and analysis reveals that cyber criminals use electronic payment

systems and virtual currencies5 as a way to launder money and to purchase or sell cyber goods

and services in furtherance of their criminal objectives.8 Bitcoin, like these other virtual

currencies, provides opportunities for criminals to transfer, launder, or steal funds. Bitcoin is

unique because it is the only decentralized, P2P network-based virtual currency. The way it

creates, operates, and distributes bitcoins makes it distinctively susceptible to illicit money

transfers, and manipulation through the use of malware and botnets.

3 (U) See Appendix C for a description of how Bitcoin works.

4 (U) The Bitcoin source code is hosted on Github (https://github.com/bitcoin/bitcoin), a code sharing Web site

where developers can work and submit changes. According to bitcoin.org there is a group of six core developers.

These developers presumably control which changes are accepted on Github.

5 (U) For example, WebMoney, Liberty Reserve and Pecunix.

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(U//FOUO) All Bitcoin transactions are published online,9 but the only information that

identifies a Bitcoin user is a pseudorandomly6 generated Bitcoin address, making the

transactions somewhat anonymous (see text box). This potential anonymity is distinct from the

anonymity provided by other electronic payment systems. For example, WebMoney and Liberty

Reserve – which may allow users to register with false information, let suspicious activity go

unnoticed, or are located in a country that is not friendly to US law enforcement – still operate as

companies with centralized organization capable of instituting programs to ensure compliance

with the Bank Secrecy Act (BSA).

(U//FOUO) As a decentralized digital currency system, Bitcoin lacks a centralized entity10 and is

incapable of conducting due diligence (e.g., regulatory guidelines), monitoring and reporting

suspicious activity, running an anti-money laundering compliance program, or accepting and

processing legal requests like subpoenas.

(U) Bitcoins Used to Purchase Illicit Goods

(U//FOUO) The FBI assesses with medium confidence that, in the near term, cyber criminals

will treat Bitcoin as another payment option alongside more traditional and established virtual

currencies such as WebMoney, which they have little reason to abandon. This assessment is

6 (U) Bitcoin addresses are pseudorandom – defined by freedictionary.com as “of, relating to, or being random

numbers generated by a definite, nonrandom computational process”.

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(U) How Anonymous is Bitcoin?

(U) Bitcoin’s anonymity depends on the actions of the user. While some news articles have lauded Bitcoin as

“untraceable digital currency,”11 the “About Bitcoin” page on bitcoin.org does not list anonymity as a feature of the

currency.12 All Bitcoin transactions are published online and Internet Protocol (IP) addresses are linked to the public

Bitcoin transactions. If a user does not anonymize his or her IP address, an interested party can identify the

individual’s physical location.13,14 Additionally, in July 2011 researchers from the University College Dublin,

Ireland, demonstrated “the inherent limits of anonymity when using Bitcoin” by conducting passive analysis of

various types of public Bitcoin information, such as transaction records and user postings of public-private keys.

The researchers suggest that law enforcement agencies or other centralized services (such as exchangers or retailers)

who have access to less public information (bank account information or shipping addresses) can connect even more

real world identifiers to Bitcoin wallets and transaction histories.15

(U) What Users Can Do To Increase Anonymity16,17,18,19

· (U)Create and use a new Bitcoin address for each incoming payment.

· (U) Route all Bitcoin traffic through an anonymizer.

· (U) Combine the balance of old Bitcoin addresses into a new address to make new payments.

· (U) Use a specialized money laundering service.

· (U) Use a third-party eWallet service to consolidate addresses. Some third-party services offer the option of

creating an eWallet that allows users to consolidate many bitcoin address and store and easily access their

bitcoins from any device.

· (U) Individuals can create Bitcoin clients to seamlessly increase anonymity (such as allowing user to

choose which Bitcoin addresses to make payments from), making it easier for non-technically savvy users

to anonymize their Bitcoin transactions.

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(U) Decentralized Authority Vulnerabilities

· (U) No anti-money laundering software or

monitoring capabilities to identify suspicious

monetary patterns.

· (U) No identification of account owners or

their actual location.

· (U) No historical records of transactions

associated with real world identity.

· (U) More difficult to identify the original

source of funds compared to other online

currencies.

· (U) Law enforcement cannot target one

central location or company for investigative

purposes or to shut down the system.

based on fluctuations in the bitcoin exchange rate in 2011 and limited reporting indicating

bitcoins are being accepted as payment by some cyber criminals. If the exchange rate for bitcoins

stabilizes7 and Bitcoin becomes more widely accepted by vendors and illicit sellers on the

Internet, cyber criminals may increasingly use bitcoins to purchase illegal goods and services and

to fund illegal activities.

· (U//FOUO) As of October 2011, a cyber criminal selling a ZeuS botnet Trojan advised

that he only accepted payments through Bitcoin, Liberty Reserve, or WebMoney,

according to a collaborative source with good access, whose information has not been

corroborated.20

· (U) According to open source reporting as of June 2011, an online marketplace called

Silk Road was selling illegal drugs and only accepted payment through Bitcoin. Silk

Road allowed parties to communicate anonymously for the purchase and sale of illegal

goods, to include the purchase of illegal narcotics, in addition to using Bitcoin.

Customers could also leave feedback about their purchase experience in a system similar

to other online sellers.21

· (U//FOUO) As of June 2011, a member of the online hacktivist group LulzSec was using

Bitcoin to purchase a botnet, according to an FBI source, some of whose reporting had

been corroborated but that had been reported for less than one year.22

· (U//FOUO) According to open source reporting, as of June 2011 a member of LulzSec

claimed the group had received over $18,000 in Bitcoins from fans and supporters.23

Bitcoin allowed LulzSec to receive

donations without revealing the

identities of the owners or the

recipients. LulzSec provided updates

about the donations they received by

thanking donors publicly via status

updates on the social networking site

Twitter.

(U) Money Laundering

(U//FOUO) The FBI assesses with low

confidence that malicious actors will exploit

Bitcoin to launder money. The confidence

level is based on observed criminal activities,

investigations, and prosecutions of individuals

laundering money through other virtual

currencies, such as e-Gold and WebMoney. A

lack of reporting specific to Bitcoin restricts

7 (U) In 2011 the exchange rate for bitcoins fluctuated from about $1/bitcoin in February to $30/bitcoin on 8 June to

about $5/bitcoin in October. (www.bitcoincharts.com)

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the confidence level. Since Bitcoin does not have a centralized authority (see text box on page

six), law enforcement faces difficulties in detecting suspicious activity, identifying users, and

obtaining transaction records – problems that might attract malicious actors to Bitcoin. If Bitcoin

becomes more widely accepted among vendors and users, the FBI anticipates seeing increased

Bitcoin money laundering activities.

· (U//FOUO) As of June 2011, organized criminal groups were using an online roleplaying

game to facilitate money laundering by purchasing virtual game currency with

the proceeds of criminal activity, according to an FBI sub-source of unknown reliability

whose reporting has not been corroborated. The virtual game currency was used to

purchase in-game virtual items that were then sold to other players for “clean money.”24

· (U//FOUO) In August 2010 an FBI source with direct access but of undetermined

reliability stated that he used fake names to register for WebMoney, a virtual currency

eletronic payment system, accounts which he used as part of a money laundering service.

The source catered to cyber criminals who earned money from carding activities but who

were not able to transfer money out of the United States by themselves.25

(U//FOUO) The FBI further assesses with medium confidence, based on previously witnessed

misuse of other virtual currencies, that malicious actors could increase their anonymity by

laundering their bitcoins through third-party Bitcoin services registered outside the US. Some of

these services act as exchangers or transmitters (see text box on page eight) that convert virtual

currencies to fiat currencies (or other virtual currencies) or transfer bitcoins between members.

Offshore services may provide additional anonymity by allowing currency exchange or money

transfer without verifying user identification or enforcing any monetary exchange limits.

· (U//FOUO) As of June 2010 unknown subjects created 3,000 online membership

accounts using 16,000 bank accounts at a US banking institution, according to a source

with direct access and whose information has been corroborated. Using the online

accounts, the perpetrators obtained fraudulent funds from victims by receiving payments

for nonexistent auction items; these funds were then used to purchase gold from gold

farmers. The subjects then sold this gold for real money – to others not linked to the

malicious actors – using a dedicated third-party service.26

· (U//FOUO) As of February 2009, an identified individual operated a Web site offering

money laundering services where cyber criminals could view the progress of their

transactions, according to a reliable, collaborative source with excellent access. The

individual laundered money using WebMoney.27

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(U) Theft of Bitcoins

(U//FOUO) The FBI assesses with high confidence, based on reliable industry and FBI reporting,

that criminals intending to steal bitcoins can target and exploit third-party Bitcoin services and an

individual’s Bitcoin wallet, principally because there is no central Bitcoin server to compromise.

Malicious actors can compromise personal computers and accounts using malware and hacking

techniques to steal users’ bitcoins. Additional techniques involve the creation of botnets to

compromise victim computers and servers instructing them to mine bitcoins.

· (U) In mid-June 2011 researchers from a major computer security firm, whose reporting

has been reliable in the past, discovered the malware “Infostealer.Coinbit” – the first

malware designed to steal bitcoins from compromised users’ Bitcoin wallet. The malware

is capable of infecting users’computers and transferring their digital Bitcoin wallet to a

server in Poland.36

· (U) In June 2011 a Bitcoin user posted a message on a Bitcoin forum stating that 25,000

of their bitcoins has been stolen from an unencrypted Bitcoin wallet on their

computer.37, 38, 39 At the June exchange rate of about $20 per bitcoin, the estimated value

of the loss was $500,000.

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(U) Third-Party Bitcoin Services

(U) Bitcoin, like most virtual currencies, requires individuals to use a third-party service to trade bitcoins for fiat

currency. Buying, selling, or trading in bitcoins – or converting bitcoins into another currency – must be done

using third-party businesses outside the Bitcoin P2P system. The number and diversity of these third-party

businesses provide users with options for moving and potentially laundering their money. 28,29,30

(U) Various third-party bitcoin services can, or are used to, facilitate trade between individuals and businesses,

buy and sell bitcoins, or convert bitcoins into other currencies.31 Users who do not want to use an intermediary

third-party can also post “buy” and “sell” orders on #bitcoin-otc, a Bitcoin marketplace located on the freenode

Internet relay chat (IRC) network. 32, 33

(U) In July 2011 FinCEN revised the definition of “money transmission service” to mean “the acceptance of

currency, funds, or other value that substitutes for currency from one person and the transmission of currency,

funds or other value to another location or person by any means.” It is likely that the business models of many

third-party bitcoin services qualify them as money transmitters, and therefore money services businesses (MSB),

under 31 CR Part 1010.100(ff)(5). Third-party bitcoin services that qualify as money transmitters and who wish

to operate legitimately must register with FinCEN, implement anti-money laundering programs, retain certain

records, and file suspicious activity reports and currency transactions reports as required. Additionally, since any

third-party Bitcoin service that falls under the MSB rule would do so as a money transmitter, there is not a

transaction threshold (such as 1,000 per day) that must be met for the regulations to apply, unlike dealers in

foreign exchange or issuers or sellers of checks or monetary instruments.34 (Note: In certain states, third-party

bitcoin services would also be required to obtain a state license).

(U//FOUO) Law enforcement might have opportunities to discover real user identifying information from some

third-party Bitcoin services because users must provide the services with real payment account information to

buy, sell, trade, and convert their bitcoins. For example, the Terms of Service for the third-party bitcoin trading

platform Mt. Gox states “members agree to provide Mt. Gox with accurate, current and complete information

about themselves as promoted by the registration process, and keep such information updated.”35

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· (U) On 19 June 2011, a compromise involving the third-party bitcoin trading platform

Mt. Gox led to an attempt to sell $7 million in bitcoins, driving the trading price to near

zero before trading was suspended. 40, 41, 42

· (U//FOUO) According to a complaint received by the FBI’s Internet Crime Complaint

Center in April 2011, an individual had 680 bitcoins stolen from his online game site. At

the time of this incident the market price was $8 per bitcoin, creating a loss of $5,440.43

(U) Theft of Services for the Purpose of Mining Bitcoins

(U//FOUO) FBI and open source reporting indicates that malicious actors can exploit the way

bitcoins are generated by compromising victim computers and instructing them to mine bitcoins.

Criminals first install malware on a victim’s computer, then use these compromised computers to

generate bitcoins.

· (U/FOUO) An identified Internet security researcher who has reported reliability in the

past identified ZeuS malware that installed software that mined bitcoins. This ZeuS

software was spread by links placed on an identified social networking site.44

· (U) According to unconfirmed open source reporting from a major periodical whose

reporting has proven reliable in the past, a botnet made up of 100,000 infected computers

could be used to generate $7,500 worth of bitcoins per day, at late June 2011 exchange

rates, by using the computing resources of victim machines.45

(U) Since large-scale bitcoin mining requires a large amount of costly processing power and

electrical energy, some miners have resorted to “borrowing” processing power from large

computing clusters through computer intrusion. In addition to unauthorized access to networks,

there have been incidents where unauthorized use of a network had been linked to Bitcoin

mining.

· (U//FOUO) FBI reporting from a reliable source indicated that in late May 2011, an

unknown actor used several machines on a computing cluster at an identified Midwestern

university to manufacture bitcoins.46 As of 26 May 2011, two IP addresses were used to

compromise 22 machines and six computer clusters. On 29 May 2011, two different IP

addresses compromised an additional five workstations and two computer clusters. The

unknown actor then used the compromised computers to access networks at three other

identified universities and tried to gain access to two government facilities.47

· (U//FOUO) According to unconfirmed open source reporting, a system administrator for

a college near New York City admitted in a May 2011 interview to using the school’s

computers for Bitcoin mining unbeknownst to the school.48

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(U) Outlook and Implications

(U//FOUO) Bitcoin will likely continue to attract cyber criminals who view it as a means to

transfer, launder, or steal funds as well as a means of making donations to groups participating in

illegal activities, such as hactivists. As long as there is a means of converting bitcoins into real

money, criminal actors will have an incentive to steal them. Since maintaining anonymity while

using Bitcoin requires that users not exchange or transfer their bitcoins using third-party bitcoins

services that require real world account information, the use of bitcoins to make donations to

disreputable groups (which can be done within the Bitcoin P2P system) will likely remain one of

the most popular uses for the virtual currency.

(U//FOUO) If Bitcoin stabilizes and grows in popularity, it will become an increasingly useful

tool for various illegal activities beyond the cyber realm. For instance, child pornography and

Internet gambling are illegal activities already taking place on the Internet which require simple

payment transfers. Bitcoin might logically attract money launderers, human traffickers, terrorists,

and other criminals who avoid traditional financial systems by using the Internet to conduct

global monetary transfers.

(U//FOUO) Although Bitcoin does not have a centralized authority, the FBI assesses with

medium confidence that law enforcement can discover more information about, and in some

cases identify, malicious actors, if the actors convert their bitcoins into a fiat currency. Thirdparty

bitcoin services may require customers to submit valid identification or bank information

to complete transactions. Furthermore, any third-party service that qualifies as a money

transmitter, and therefore a MSB, must register with the FinCEN and implement an anti-money

laundering program.49

(U) Intelligence Gaps

· (U//FOUO) Who is using Bitcoin to circumvent BSA regulations (e.g., money

launderers)?

· (U//FOUO) Which third-party Bitcoin services support illegal activity?

· (U//FOUO) Which criminal, nation state, and terrorist organizations are using Bitcoin to

finance their operations?

(U) Intelligence Collection Requirements Addressed in Paper

(U//FOUO) This intelligence assessment will address requirements contained in the following

FBI National Standing Collection Requirements topics: Botnets contained in WW-BOT-CYDSR-

0027-11, Money Laundering contained in USA-MLA-CID-0032-10, Cyber Intrusions

with a Criminal Nexus contained in WW-CYBR-CYD-SR-0061-10, and Virtual Worlds/Online

Games contained in WW-CYBER-CYD-SR-0028-11.

(U) This assessment was prepared by the Domestic Threats Cyber Intelligence Unit, Technology Cyber Intelligence

Unit, and the Financial Crimes Intelligence Unit of the FBI. Comments and queries may be addressed to the unit

chiefs at 202-651-3051, 202-651-3139 or 202-324-8629, respectively.

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(U) Appendix A: Key Terms

(U) Bitcoin wallet: A data file that stores bitcoin currency (see appendix C). A user downloads

software to a personal computer or may use an online, third-party provider to create a wallet

(often called an eWallet) to store bitcoins.

(U) Botnets: Any group of two or more computers and/or mobile devices that are controlled

and/or updated remotely for an illegal purpose. Botnets can be used to perform denial of service

attacks, send spam e-mail, host illegal content, and may aid in most other types of online

criminal behavior.

(U) Carding: the act of trafficking and/or fraudulent use of stolen credit card account

information.

(U) Decentralized: No central administration, issuing authority, or database.

(U/FOUO) Cyber underground: The extensive network of members engaged in cyber crime

activities that have a unique language, an underground economy, a set of expectations about its

members’ conduct, and a system of social stratification based on knowledge, skill, and activities.

(U) Electronic payment systems: Provide a secure means of transferring money among parties

to facilitate e-commerce and operate using real money or virtual currency. Electronic payment

systems either allow payment to be made between users, vendors, and other merchants, or they

only allow payments to be made between users or accounts. There is both a regulated sector and

a sector operating outside regulatory systems.

(U) Exchangers: Online entities that, for a fee, convert cash, virtual currency, or digital gold

currency into the type of currency requested. In general, individuals must use an exchanger to

deposit money into an electronic payment system account, unless the electronic payment system

has a physical location. Due to this fact, exchangers are a vital part of the money flow for

electronic payment systems and virtual currencies.

(U) Fiat Currency: Money that has value solely due to government regulation or law. Most

modern currencies, such as the US dollar and the Euro are fiat currencies.

(U) Freenode: An open source software-focused Internet relay chat network.

(U) Hacktivists: Individuals or groups who attack computer systems to draw attention to a

particular issue, influence public opinion, or punish perceived entities who oppose their

ideological positions.

(U) Internet Relay Chat (IRC): A form of real-time Internet synchronous conference, mainly

designed for group communication in discussion forums called channels, but also allowing oneto-

one communication via private messages.

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(U) Malware or malicious software: Computer software that facilitates illicit activities, to

include data exfiltration, denial of service attacks, fraud, and spam dissemination.

(U) Mining, Bitcoin (also known as Bitcoin Creation, Bitcoin Generation, and Bitcoin

Manufacturing): The process of allowing the Bitcoin network to use a computer’s resources in

exchange for the possibility of earning bitcoins. The more computing power a user offers, the

more likely they are to receive bitcoins.

(U) Money services business (MSB): Any person doing business in one or more of the

following capacities, wholly or in substantial part within the United Sates: 1.) dealer in a foreign

exchange; 2.) check casher; 3.) issuer or seller of traveler’s checks or money orders; 4.) issuer,

seller, or redeemer of stored value; 5.) money transmitter; 6.) U.S. Postal Service (31 C.F.R

103.11).50

(U) Money transmitter: A person that provides money transmission services. The term “money

transmission services” means the acceptance of currency, funds, or other value that substitutes

for currency from one person and the transmission of currency, fund, or other value that

substitutes for currency to another location or person by any means.51

(U) Peer-to-Peer (P2P): A type of network in which each workstation has equivalent

capabilities and responsibilities. P2P is typically used for the transfer of data from one peer to

another and are free programs that can be easily downloaded from the Internet. P2P file-sharing

is the primary source for pirated software. Some popular examples include Limewire, Kazaa, and

Gnutella.

(U) Public Key Cryptography (PKI): A framework for creating a secure method for

exchanging information based on public key cryptography. PKI uses a certificate authority (CA),

which issues digital certificates that authenticate the identity of organizations and individuals

over a public system such as the Internet.

(U) Real money: Coins or paper notes issues and backed by a government and used as a

medium of exchange and measure of value.

(U) Virtual currency: Something used on the Internet that is in circulation as a medium of

exchange but is not backed by a government.

(U) ZeuS Trojan: malicious software used by cyber criminals to steal online account

credentials.

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Appendix B: Confidence Levels

(U) High confidence generally indicates that FBI judgments are based on high-quality

information from multiple sources or a single highly reliable source, or that the nature of the

issue makes it possible to render a solid judgment.

(U) Medium confidence generally means that the information is interpreted in various ways,

that the FBI has alternating views, or that the information, while credible, is of insufficient

reliability to warrant a higher level of confidence.

(U) Low confidence generally means that the information is scant, questionable, or very

fragmented; that it is difficult to make solid analytic inferences; or that the FBI has significant

concerns or problems with the source.

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(U) Appendix C: How Does Bitcoin Work?

(U) To use Bitcoin, an individual first downloads and installs the free Bitcoin software (client).

The application uses Public Key Cryptography (PKI) to automatically generate a Bitcoin address

where the user can receive payments. The address is a unique 36 character-long string of

numbers and letters and is stored in a user’s virtual “wallet” on his or her local file system. Users

can create as many Bitcoin addresses as they like to receive payments and can use a new address

for every transaction they receive.

(U) To send bitcoins, users input the address they would like to send their bitcoins to and the

amount of bitcoins they would like to transfer. The user’s computer then digitally signs the

transaction and sends the information to the distributed, P2P Bitcoin network. The P2P network

verifies that the person sending the bitcoins is the current owner of the bitcoins they are sending,

prohibiting a malicious user from spending the same bitcoins twice. Once the transaction has

been validated by the Bitcoin network, receivers can spend the bitcoins they have received. This

process usually takes a few minutes and is not reversible.

(U) The Bitcoin software program controls the rate of bitcoin creation, but it does not control the

market value of a bitcoin; the market value is determined by the supply of bitcoins in circulation

and people’s desire to hold or trade bitcoins.52, 53 Unlike most fiat currencies, in which central

banks can arbitrarily increase the supply of currency, Bitcoin is designed to eventually contain

21 million bitcoins; no additional coins will be created after that point, preventing inflation.

(U) Bitcoin was created in such a way that the clients “mine” bitcoins at a predetermined rate.

This chart illustrates the growth rate from 2009 to 2033, the year the last new bitcoin will be

created.

Source: (U) Internet site; Bitcoin Wiki; “Controlled Currency Supply”;

https://en.bitcoin.it/wiki/Controlled_Inflation; accessed in 5 March 2012; The source is a community wiki aimed at

allowing anyone to freely document information about Bitcoin. Users must create a free account with a valid e-mail

address to edit the Bitcoin Wiki.

UNCLASSIFIED//FOR OFFICIAL USE ONLY

UNCLASSIFIED//FOR OFFICIAL USE ONLY

Distribution

DI/OCA

LEO

SIPRNet

JWICS

NCTC S and TS

LNI

Australian Federal Police (AFP)

Metropolitian Police – Police Central e-Crime Unit (PCeU)

New Zealand Police

Royal Canadian Mounted Police (RCMP)

Serious Organised Crime Agency (SOCA)

UNCLASSIFIED//FOR OFFICIAL USE ONLY

UNCLASSIFIED//FOR OFFICIAL USE ONLY

(U) Endnotes

1 (U) Internet site; Bitcoincharts.com; “Mt. Gox (USD/dwolla/SEPA)”;

http://bitcoincharts.com/markets/mtgoxUSD.html; accessed on 18 April 2012; the source provides financial and

technical data related to the Bitcoin network and uses daily intervals to display information. While this information

may contain biases, the FBI assumes the information is generally indicative of the true state of the Bitcoin economy.

2 (U) Internet site; Bitcoin Block Explorer; “total bc”; http://blockexplorer.com/q/totalbc; accessed on 18 April

2012; The source is a Web site that posts information about Bitcoin transaction based on code developed by a

volunteer. While this may contain inaccuracies, the FBI assumes the information is generally indicative of the true

state of the Bitcoin economy.

3 (U) Internet site; Bitcoincharts.com; “Markets”; http://bitcoincharts.com/markets; accessed on 18 April 2012; the

source provides financial and technical data related to the Bitcoin network and uses daily intervals to display

information. While this information may contain biases, the FBI assumes the information is generally indicative of

the true state of the Bitcoin economy.

4 (U) Internet site; Bitcoincharts.com; “Mt. Gox (USD/dwolla/SEPA)”;

http://bitcoincharts.com/charts/mtgoxUSD_trades.html; accessed on 18 April 2012; the source provides financial

and technical data related to the Bitcoin network and uses daily intervals to display information. While this

information may contain biases, the FBI assumes the information is generally indicative of the true state of the

Bitcoin economy.

5 (U) op. cit. endnote 1.

6 (U) Internet site; Github; “Bitcoin/bitcoin”; https://github.com/bitcoin/bitcoin; accessed on 19 April 2012; the

source is a code sharing Web site where developers can work and submit changes.

7 (U) Internet site; Bitcoin Wiki; “Trade”; https://en.bitcoin.it/wiki/Trade; accessed 18 April 2012; The source is a

community wiki aimed at allowing anyone to freely document information about Bitcoin. Users must create a free

account with a valid e-mail address to edit the Bitcoin Wiki. While this wiki is edited by the community and may

contain biases, the FBI assumes the information accurately reflect businesses which accept bitcoins as payment.

8 (U) FBI; Intelligence Assessment; (U) Cyber Criminal Exploitation of Electronic Payment Systems and Virtual

Currencies; 23 February 2011.

9 (U) Internet site; Bitcoin Block Explorer; http://blockexplorer.com; accessed 18 April 2012; The source is a Web

site that posts information about Bitcoin transactions based on code developed by a volunteer. While this may

contain inaccuracies, the FBI assumes the information is generally indicative of the true state of the Bitcoin

economy.

10 (U) Internet site; Bitcoin.org; “About Bitcoin”; http://bitcoin.org/about.html; accessed on 9 February 2012;

Bitcoin.org is the official Web site of Bitcoin. While this information may contain biases, the FBI assumes the

information is generally indicative of the true state of the Bitcoin economy.

11 (U) Internet site; Adrian Chen; Gawker; “The Underground Website Where You Can Buy Any Drug Imaginable”;

1 June 2011; http://gawker.com/5805928/the-underground-website-where-you-can-buy-any-drug-imaginable;

accessed on 2 June 2011; The source is an online blog-oriented media site owned by Gawker Media.

12 (U) op. cit. endnote 10.

13 (U) Internet site; Bitcoin Wiki; “Network”; https://en.bitcoin.it/wiki/Network; accessed on 9 February 2012; the

source is a community wiki aimed at allowing anyone to freely document information about Bitcoin. Users must

create a free account with a valid e-mail address to edit the Bitcoin Wiki. While this wiki is edited by the community

and may contain biases, the FBI assumes the information is generally indicative of the trust state of the Bitcoin

economy.

14 (U) Internet Article; Jason Mick; Daily Tech; “Cracking the Bitcoin: Digging Into a $131M USD Virtual

Currency”; 12 June 2011;

http://www.dailytech.com/Cracking+the+Bitcoin+Digging+Into+a+131M+USD+Virtual+Currency/article21878.ht

m; accessed on 9 December 2011; The source is an online magazine publishing news, research and discussion on

current and upcoming science and information technology issues.

15 (U) Online Article; Fergal Reid and Martin Harrigan; University College Dublin; “An Analysis of Anonymity in

the Bitcoin System”; 22 July 2011 ; http://arxiv.org/PS_cache/arxiv/pdf/1107/1107.4524v1.pdf ; accessed on 20

December 2011; The authors are researchers with the Clique Research Cluster at University College Dublin, Ireland.

16 (U) Internet site; Bitcoin Wiki; “Anonymity”; https://en.bitcoin.it/wiki/Anonymity; accessed on 9 February 2012;

the source is a community wiki aimed at allowing anyone to freely document information about Bitcoin. Users must

create a free account with a valid e-mail address to edit the Bitcoin Wiki. While this wiki is edited by the community

UNCLASSIFIED//FOR OFFICIAL USE ONLY

UNCLASSIFIED//FOR OFFICIAL USE ONLY

and may contain biases, the FBI assumes the information is generally indicative of the true state of the Bitcoin

economy.

17 (U) Internet site; Bitcointalk Forum; “Patching the Bitcoin Client to Make it More Anonymous”; 30 June 2011;

https://bitcointalk.org/index.php?topic=24784.msg307661#msg307661; accessed on 9 February 2012; the source is

a forum dedicated to Bitcoin discussions. While this information may contain biases, the FBI assumes the

information is generally indicative of the true state of the Bitcoin development community.

18 (U) Internet site; Timothy Lee; Forbes; “How Private are Bitcoin Transactions?”; 14 July 2011;

http://www.forbes.com/sites/timothylee/2011/07/14/how-private-are-bitcoin-transactions; accessed on 9 February

2012; the source is an adjunct scholar at the Cato institute with a master’s degree in computer science. He is a

contributed to Forbes, an Internet media company providing commentary, analysis tools and real-time reporting to

businesses and investment leaders.

19 (U) Internet site; Thomas Lowenthal; Active Rhetoric Blog; “Bitcoin: More Covert than it Looks”; 14 July 2011;

http://activerhetoric.wordpress.com/2011/07/14/bitcoin-more-covert-than-it-looks; accessed on 9 February 2012; the

source is a blog.

20 (U//FOUO) FBI; IIR; 4 213 0829 12; 12 December 2011; 18 October 2011; “(U//FOUO) Identification of

Individual Using Online Moniker ‘Cipher’ Selling a Zeus Trojan Botnet on an Identified US Web site as of October

2011”; UNCLASSIFIED//FOR OFFICIAL USE ONLY; UNCLASSIFIED//FOR OFFICIAL USE ONLY; A

collaborative source with good access, none of whose reporting has been corroborated for less than one year.

21 (U) op. cit. endnote 11.

22 (U//FOUO) FBI; 17 June 2011; June 2011; FBI Case Information; UNCLASSIFIED//FOR OFFICIAL USE

ONLY; UNCLASSIFIED//FOR OFFICIAL USE ONLY; an FBI source, some of whose reporting has been

corroborated but that has reported for less than one year.

23 (U) Internet site; The Next Web; “Lulzsec Claims to Have Received Over $18,000 in Donations”; 24 June 2011;

http://thenextweb.com/insider/2011/06/24/lulzsec-claims-to-have-received-over-18000-worth-of-donations/;

accessed on 12 October 2011; the source is a technology blog publishing news and views from an international

perspective.

24 (U//FOUO) FBI; 3 June 2011; 27 May 2011; FBI Case Information; UNCLASSIFIED; an FBI sub-source of

unknown reliability whose reporting has not been corroborated.

25 (U//FOUO) FBI; 10 August 2010; 6 August 2009; FBI Case Information; UNCLASSIFIED//FOR OFFICIAL

USE ONLY; UNCLASSIFIED//FOR OFFICIAL USE ONLY; An FBI source with first-hand access to the

information and whose reliability cannot be determined.

26 (U//FOUO) FBI; IIR; 4 213 4056 11; 15 August 2011; 9 June 2010; “(U//FOUO) Creation of Bank Accounts by

an Internet Bot For Use in a Massively Multiplayer Online Role Playing Game and E-Commerce Payment Site

Scheme, June 2010”; UNCLASSIFIED//FOR OFFICIAL USE ONLY; UNCLASSIFIED//FOR OFFICIAL USE

ONLY; the source is an FBI agent.

27 (U//FOUO) FBI; IIR; 4 213 4947 09; 11 August 2009; 18 February 2009; “(U//FOUO) Identification of Money

Laundering Web Site Operated by Individual Linked to Internet Fraud Schemes, as of February 2009”;

UNCLASSIFIED//FOR OFFICIAL USE ONLY; UNCLASSIFIED//FOR OFFICIAL USE ONLY; A collaborative

source with excellent access, much of whose reporting has been corroborated over the past two years. Source spoke

in confidence.

28 (U) Internet site: Bitcoin Wiki; “Selling Bitcoins”; https://en.bitcoin.it/wiki/Selling_bitcoins; accessed on 9

February 2012; the source is a community wiki aimed at allowing anyone to freely document information about

Bitcoin. Users must create a free account with a valid e-mail address to edit the Bitcoin Wiki. While this wiki is

edited by the community and may contain biases, the FBI assumes the information is generally indicative of the true

state of the Bitcoin economy.

29 (U) Internet site: Bitcoin Wiki; “Buying Bitcoins”; https://en.bitcoin.it/wiki/Buying_bitcoins; accessed on 9

February 2012; the source is a community wiki aimed at allowing anyone to freely document information about

Bitcoin. Users must create a free account with a valid e-mail address to edit the Bitcoin Wiki. While this wiki is

edited by the community and may contain biases, the FBI assumes the information is generally indicative of the true

state of the Bitcoin economy.

30 (U) Internet site: Bitcoin Wiki; “Secure Trading”; https://en.bitcoin.it/wiki/Secure_Trading; accessed on 9

February 2012; the source is a community wiki aimed at allowing anyone to freely document information about

Bitcoin. Users must create a free account with a valid e-mail address to edit the Bitcoin Wiki. While this wiki is

edited by the community and may contain biases, the FBI assumes the information is generally indicative of the true

state of the Bitcoin economy.

UNCLASSIFIED//FOR OFFICIAL USE ONLY

UNCLASSIFIED//FOR OFFICIAL USE ONLY

31 (U) Internet side; Jason Mick; Daily Tech; “Internet Digital Black Friday: First Bitcoin “Depression” Hits”; 10

June 2011; https://www.dailytech.com/Digital+Black+Friday+First+Bitcoin+Depression+Hits/article21877.htm;

accessed on 16 June 2011; The source is an online magazine publishing news, research, and discussion on current

and upcoming science and information technology issues.

32 (U) Internet site; Bitcoin-otc; “#bitcoin-otc marketplace”; http://bitcoin-otc.com; accessed on 14 October 2011;

The source is an online marketplace for the exchange and sales of bitcoins.

33 (U) Internet site; Bitcoin Wiki; “Using bitcoin-otc”; http://wiki.bitcoin-otc.com/wiki/Using_bitcoin-otc; accessed

on 21 June 2011; the source is a community wiki aimed at allowing anyone to freely document information about

Bitcoin. Users must create a free account with a valid e-mail address to edit the Bitcoin Wiki. While this wiki is

edited by the community and may contain inaccuracies, the FBI assumes the information is generally indicative of

the true state of the Bitcoin community.

34 (U) Online publication; Federal Register Col. 17, No. 140; “Bank Secrecy Act Regulations; Definitions and Other

Regulations Relating to Money Services Businesses”; 21 July 2011; http://www.gpo.gov/fdsys/pkg/FR-2011-07-

21/pdf/2011-18309.pdf; accessed on 9 March 2012; pages 43585-43597.

35 (U) Internet site; Mt. Gox; “Terms of Use”; 20 January 2012; https://mtgox.com/terms_of_service”; accessed on 7

March 2012; Mt. Gox is a third-party bitcoin trading platform

36 (U) Internet site; Kevin Poulsen; Wired; “New Malware Steals Your Bitcoin”; 16 June 2011;

http://www.wired.com/threatlevel/2011/06/bitcoin-malware/; accessed 23 June 2011; The source is an online

publication that provides news reporting, commentary and reviews on innovation in technology, science, business

and culture. Wired.com is part of the Conte Nast Digital Network.

37 (U) Internet site; Timothy B. Lee; Ars Technica; “A Risky Currency? Alleged $500,000 Bitcoin Heist Raises

Questions”; 15 June 2011; http://arstechnica.com/tech-policy/news/2011/06/bitcoin-the-decentralized-virtualcurrencyrisky-

currency-500000-bitcoin-heist-raises-questions.ars; accessed 2 August 2011; The source is a

technology Web site that offers a mix of news, in-depth trend analysis and how-to instruction. Arstechnica.com is

part of the Conte Nast Digital Network.

38 (U//FOUO) FBI; Internet Crime Complaint Center; Complaint Referral Form; 18 June 2011; source is a

victim/consumer complaint. The reliability cannot be determined.

39 (U) Internet Site; Bitcoin Forum, “I just got hacked – any help is welcome! (25,000 BTC stolen)”; 13 June 2011 ;

https://bitcointalk.org/index.php?topic=16457.0; accessed 1 January 2012; The source is a forum where users post

messages discussing bitcoins.

40 (U) Internet site; James Ball; The Guardian; “LulzSec Rogue Suspected of Bitcoin Hack”; 22 Jun 2011;

http://www.guardian.co.uk/technology/2011/jun/22/lulzsec-rogue-suspected-of-bitcoin-hack; accessed on 6 July

2011; The source is the online publication of the United Kingdom’s Guardian newspaper.

41 (U) Internet site; Jason Mick; Daily Tech; 19 June 211;

http://www.dailytech.com/Inside+the+MegaHack+of+Bitcoin+the+Full+Story/article21942.htm; accessed on 21

June 2011; the source is an online magazine publishing news, research and discussion on current and upcoming

science and information technology issues.

42 (U) Internet site; Sean Ludwig; VentureBeat; “Popular Bitcoin Exchange Mt. Gox Hacked, Prices Drop to

Pennies”; 19 June 2011; http://venturebeat.com/2011/06/19/popular-bitcoin-exchange-mt-gox-hacked-prices-dropto-

pennies/; accessed on 21 June 2011; the source is a blog and online news site whose stated mission is to provide

news about innovation for forward-thinking executives.

43 (U//FOUO) FBI; Internet Crime Complaint Center; Complaint Referral Form; 14 May 2011; 23 April 2011; the

source is a victim/consumer complaint and the reliability cannot be determined.

44 (U//FOUO) FBI; 2 Jun 2011; FBI Information; Source is an Internet security researcher who has reported reliably

in the past.

45 (U) op. cit. endnote 40.

46 (U//FOUO) FBI; IIR; 4 213 3647 11; 18 July 2011; 31 May 2011; “(U//FOUO) Compromise of Computer

Clusters at Identified US Universities for the Purpose of Manufacturing Virtual Currency, as of May 2011”;

UNCLASSIFIED//FOR OFFICIAL USE ONLY; SECRET//NOFORN; a collaborative source with excellent access,

much of whose reporting has been corroborated over the past two years.

47 (U//FOUO) FBI; IIR; 4 213 3754 11; 25 July 2011; May 2011; “(U//FOUO) Update to Compromise of Computer

Clusters at Identified US Universities for the Purpose of Manufacturing Virtual Currency, as of May 2011”;

UNCLASSIFIED//FOR OFFICIAL USE ONLY; UNCLASSIFIED//FOR OFFICIAL USE ONLY; a collaborative

source with excellent access, much of whose reporting has been corroborated over the past two years.

UNCLASSIFIED//FOR OFFICIAL USE ONLY

UNCLASSIFIED//FOR OFFICIAL USE ONLY

48 (U) Internet Site: motherboard.tv; “How to Get Rich on Bitcoin, by a System Administrator Who’s Secretly

Growing Them on His School’s Computers”; 27 May 2011; http://www.motherboard.tv/2011/5/27/how-to-get-richon-

bitcoin-by-a-system-administrator-who-s-secretly-growing-them-on-his-scool-s-computers; accessed on 14

October 2011; the source is a Web site dedicated to the meeting point of science, technology, and culture. It is

powered by a community of writers and video producers.

49 (U) Online publication; Federal Register Col. 76, No. 140; “Bank Secrecy Act Regulations; Definitions and Other

Regulations Relating to Money Services Businesses” 21 July 2011; http://www.gpo.gov/fdsys5/pkg/FR-2011-07-

21/pdf/2011-18309.pdf; accessed on 9 March 2012; page 43596.

50 (U) Online publication; Federal Register Vol. 76, No. 140; “Bank Secrecy Act Regulations; Definitions and Other

Regulations Relating to Money Services Businesses”; 21 July 2011; http://www.gpo/gov/fdsys/pkg/FR-2011-07-

21/pdf/2011-18309.pdf; accessed on 9 March 2012; pages 43585-43597.

51 (U) Online publication; Federal Register Vol. 76, No. 140; “Bank Secrecy Act Regulations; Definitions and Other

Regulations Relating to Money Services Businesses”; 21 July 2011; http://www.gpo/gov/fdsys/pkg/FR-2011-07-

21/pdf/2011-18309.pdf; accessed on 9 March 2012; pages 43596.

52 (U) Internet site; Bitcoin Wiki; “FAQ Page”; http://en.bitcoin.it/wiki/FAQ/; accessed on 20 January 2012; the

source is a community wiki aimed at allowing anyone to freely document information about Bitcoin. Users must

create a free account with a valid e-mail address to edit the Bitcoin Wiki. While this wiki is edited by the community

and may contain biases, the FBI assumes the information is generally indicative of the true state of the Bitcoin

economy.

53 (U) Internet site; Stephen Chapman; ZDNet; “Bitcoin: A Guide to the Future of Currency”; 15 June 2011;

http://www.zdnet.com/blog/btl/bitcoin-a-guide-to-the-future-of-currency/50601; accessed on 21 June 2011; the

source, available in seven regional editions, is an online resource of technology-related issues featuring blogs,

product reviews, software downloads, white papers and research.

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