I love that you’re bringing discussion of the specific proposals.
I don’t know about the specific finances of FTX, but I do know about audits. Auditors work based on norms, and those norms get better at predicting new disasters by learning from previous disasters (such as Enron). The same is true of air travel, one of “the safest ways of travel”.
My guess is that the only way in which alarms would’ve ringed for FTX investors was by realizing that there was a “back door” where somebody could just steal all the money. Would a financial auditor have looked into that, the programming aspect of the business? I doubt it, unless specific norms were in place to look for just that.
I think that there are two specific disasters here:
SBF’s fraud, and
SBF harming the EA “brand”?
If what we want is to avoid future fraud in the Crypto community, then the goal of the Crypto community should be to replicate the air travel model for air safety[1]:
Strong (and voluntary) inter-institutional cooperation, and
A post-mortem of every single disaster in order to incorporate not regulation but “best practices”.
However, if the goal is to avoid harming the EA “brand”, then there’s a profession for that. It’s called “Public Relations”.
PR it’s also the reason why big companies have rules that prevent them from (publicly) doing business with people suspected of doing illegal activities. (“The wife of the Caesar must not only be pure, but also be free of any suspicios of impurity”)
For example, EA institutions could from now on:
Copy GiveDirectly’s approach and avoid any single donor from representing more than 50% of their income.
Perhaps increase or decrease that percentage, depending on the impact in SBF’s supported charities.
Reject money that comes from Tax Havens.
FTX was a business based mainly in The Bahamas.
I don’t know what is the quality of the Bahamas standard for financial audits. In fact, I don’t even know if they demand financial audits at all… but I know that The Bahamas is sometimes classed as a Tax Haven, and is more likely that we find criminals and frads with money in Tax Haven than outside of them.
Incentivize their own supported charities to reject dependence on a single donor, and to reject money that comes from Tax Havens.
Perhaps also...
… Campaign against Tax Havens?
Tax Havens crowd out against money given to tax-deductible charities, and therefore for EA Charities.
There is an economic benefit to some of the citizens of the Tax Haven countries, but when weighted against the criminal conduct that they enable… are they truly more good than bad?
… Create a certification for NGOs to be considered “EA”?
Most people know that some causes (Malaria treatments, Deworming...) are well-known EA causes.
They are causes that attract million of dollars in funding.
Since there is no certification for NGO0s to use the name “EA”, a fraudster-in-waiting can just
Start a new NGO tomorrow.
“Brand” itself as an EA charity
See the donations begin to pour-in, and
Commit fraud in a new manner that avoids existing regulation
Profit
Give the news cycle an exciting new story, and the EA community another sleepless night.
In fact, fraud in NGO’s happens all the time. One of the reasons why Against Malaria Foundation had trouble implementing their first Give Well charity is that they were too stringent on the anti corruption requirements for governments.
It’s in the direct interest of the EA community to minimize the amount of fraudulent NGO’s, and to minimize the amount of EA branded fraudulent NGO’s.
In fact, at the same time that we’re discussing this, a tragic air travel accident happened on a Dallas Airshow. Our efforts might be more “effective” by not discussing SBF and instead discussing Airshow Security and their morality.
My problem with post mortem or investigations is that it is late of a reaction, EA image has been tarnished and the total cost of a scandal could not be computed. I still believe that installing a dedicated governance team reviewing all of the major risks where inflows and outflows of money is involved is still a better approach.
Requiring and reviewing financial statements audited by a big 4 firm is still the best approach if a certain charity/Non profit org is receiving a donation—assuring that the donor is doing its best to comply with international or American accounting standards. Audited FS submissions also solves the tax haven comment you shared though I believe legitimate companies still do have accounting standards and audit standards especially as they still need to engage in the business world. It was described that SBF has a backdoor mechanism in their books that evaded executives, accountants and auditors—if this is true, the tax haven issue is not the culprit. Btw, I live in the nearby Cayman Islands and we still do accounting here following International Accounting Standards.
I have no problems with strong inter institutional cooperation but it still needs some kind of system to work with like who plays the lead and the follower in certain scenarios
I love that you’re bringing discussion of the specific proposals.
I don’t know about the specific finances of FTX, but I do know about audits. Auditors work based on norms, and those norms get better at predicting new disasters by learning from previous disasters (such as Enron). The same is true of air travel, one of “the safest ways of travel”.
My guess is that the only way in which alarms would’ve ringed for FTX investors was by realizing that there was a “back door” where somebody could just steal all the money. Would a financial auditor have looked into that, the programming aspect of the business? I doubt it, unless specific norms were in place to look for just that.
I think that there are two specific disasters here:
SBF’s fraud, and
SBF harming the EA “brand”?
If what we want is to avoid future fraud in the Crypto community, then the goal of the Crypto community should be to replicate the air travel model for air safety[1]:
Strong (and voluntary) inter-institutional cooperation, and
A post-mortem of every single disaster in order to incorporate not regulation but “best practices”.
However, if the goal is to avoid harming the EA “brand”, then there’s a profession for that. It’s called “Public Relations”.
PR it’s also the reason why big companies have rules that prevent them from (publicly) doing business with people suspected of doing illegal activities. (“The wife of the Caesar must not only be pure, but also be free of any suspicios of impurity”)
For example, EA institutions could from now on:
Copy GiveDirectly’s approach and avoid any single donor from representing more than 50% of their income.
Perhaps increase or decrease that percentage, depending on the impact in SBF’s supported charities.
Reject money that comes from Tax Havens.
FTX was a business based mainly in The Bahamas.
I don’t know what is the quality of the Bahamas standard for financial audits. In fact, I don’t even know if they demand financial audits at all… but I know that The Bahamas is sometimes classed as a Tax Haven, and is more likely that we find criminals and frads with money in Tax Haven than outside of them.
Incentivize their own supported charities to reject dependence on a single donor, and to reject money that comes from Tax Havens.
Perhaps also...
… Campaign against Tax Havens?
Tax Havens crowd out against money given to tax-deductible charities, and therefore for EA Charities.
There is an economic benefit to some of the citizens of the Tax Haven countries, but when weighted against the criminal conduct that they enable… are they truly more good than bad?
… Create a certification for NGOs to be considered “EA”?
Most people know that some causes (Malaria treatments, Deworming...) are well-known EA causes.
They are causes that attract million of dollars in funding.
Since there is no certification for NGO0s to use the name “EA”, a fraudster-in-waiting can just
Start a new NGO tomorrow.
“Brand” itself as an EA charity
See the donations begin to pour-in, and
Commit fraud in a new manner that avoids existing regulation
Profit
Give the news cycle an exciting new story, and the EA community another sleepless night.
In fact, fraud in NGO’s happens all the time. One of the reasons why Against Malaria Foundation had trouble implementing their first Give Well charity is that they were too stringent on the anti corruption requirements for governments.
It’s in the direct interest of the EA community to minimize the amount of fraudulent NGO’s, and to minimize the amount of EA branded fraudulent NGO’s.
In fact, at the same time that we’re discussing this, a tragic air travel accident happened on a Dallas Airshow. Our efforts might be more “effective” by not discussing SBF and instead discussing Airshow Security and their morality.
Great points here.
My problem with post mortem or investigations is that it is late of a reaction, EA image has been tarnished and the total cost of a scandal could not be computed. I still believe that installing a dedicated governance team reviewing all of the major risks where inflows and outflows of money is involved is still a better approach.
Requiring and reviewing financial statements audited by a big 4 firm is still the best approach if a certain charity/Non profit org is receiving a donation—assuring that the donor is doing its best to comply with international or American accounting standards. Audited FS submissions also solves the tax haven comment you shared though I believe legitimate companies still do have accounting standards and audit standards especially as they still need to engage in the business world. It was described that SBF has a backdoor mechanism in their books that evaded executives, accountants and auditors—if this is true, the tax haven issue is not the culprit. Btw, I live in the nearby Cayman Islands and we still do accounting here following International Accounting Standards.
I have no problems with strong inter institutional cooperation but it still needs some kind of system to work with like who plays the lead and the follower in certain scenarios