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tency between at least similar implementations is   8.4.3   Issue: Monopolistic Possibilities in DLT Use
            desirable to avoid unnecessary fragmentation that
            would delay the emergence of industry ‘standards’   Dimensions Affected: Network, Consensus, Data
            for a sector.                                      Model, Execution, Application, External
                                                               While the DLT ecosystem is still nascent, consider-
            8.4.2   Issue: Denial of Service                   ations of risks to fair competition still arise. This may
                                                               manifest as inability for others to participate in the
            Dimensions Affected: Network, Consensus,           DL or allowing interoperability with other DLs; inabil-
            External                                           ity to access encryption key or access to technolo-
                                                               gies based on enforcement of patents in a relatively
            Specific Threat: Distributed Denial of Service     new market. These barriers may arise by technology
            (DDoS)                                             design or because of market development.  226
            DDoS attacks represent an effort to disrupt the      Consortium, permissioned DLTs may be prone to
            operation of a target system through the consump-  inherent competition-related concerns. Simply, they
            tion of its resources with an overwhelming number   amount to a closed group, with in most cases high
            of requests to be processed. In order to maximize   qualification barriers.  In developing these plat-
                                                                                  227
            impact as well as avoiding detection, networks     forms, there will invariably need be collaborative
            of ‘zombie’ computers controlled by an attacker    efforts necessary to implement the chosen DLT to the
            (also known as ‘botnets’) may be used. From 2014-  particular use case within a vertical. Internal gover-
            2015, dozens of attacks were reported,  currency   nance may ameliorate or exacerbate these concerns,
                                                217
            exchanges and mining pools were primary targets on   especially if there are governing bodies made of up of
            the Bitcoin network,  with over 60% of large Bitcoin   members who have the power to include or exclude
                              218
            mining pools suffering DDoS attacks versus only 17%   members.  Cross-border jurisdictional issues may
                                                                       228
            for smaller pools.                                 complicate enforcement by market integrity regula-
                           219
                                                               tors, if they can found jurisdiction over DLTs.
            Vulnerability:
            While DDoS attacks  are more  difficult  to accom-  Risks:
            plish on a decentralized, distributed network, DDoS   Lack of practical on-chain interoperability between
            remains a very popular method of attack on cryp-   DLT raises competition concerns, with balkanization
            to-currency networks. They are more impactful when   of DLTs and with exclusion from technologies and
            focused on a greater concentration of miners (and   data possible across vertical asset classes. Similarly,
            validators), such as the Bitcoin network where sever-  mining pools undertaking POW could monopolize
            al large mining pools operate.                     some DLTs or change the underlying protocols.
                                      220
            Risks:                                             Mitigation & Recommendations:
            An attack on a sizeable mining pool can substan-   Market conduct regulators would have to consid-
            tially disrupt mining activity  and even early detec-  er whether there is a dominance of a DLT within a
                                     221
            tion and preventative measures can still result be of   particular market activity. However, with the rapid
            significant negative impact.  Attacks on a network   evolution of DLs, competition law and regulators
                                     222
            (or competing mining pool) may also be placed to   may struggle to define these markets, a determina-
            cause actors to unnecessarily consume resources, be   tion that may also be complicated by cross-jurisdic-
            it disrupting a network by occupying nodes with a   tional issues.
            flurry of fake or invalid requests or other activities
            which may burn Gas and cost money to place blocks   8.4.4   Issue: Reliance on and Trust in DLT Nodes
            in a state they were in before the DDoS attack.    Despite the use of strong cryptography, DLTs are not
                                                               necessarily a panacea for security concerns people
            Mitigation and Recommendations:                    may have.  Indeed, there is a trade-off between
                                                                        229
            While the Bitcoin client has DDoS prevention meth-  replacing costly – and often risky - intermediar-
            ods,  they are not bulletproof and mining pools and   ies with cryptographic key-only access distribut-
                223
            exchanges typically obtain specialized DDoS mitiga-  ed across nodes.  For example, for permissioned
                                                                              230
            tion and prevention services, such as those provid-  ledgers replacing centralized intermediaries, the
            ed by Incapsula  or Cloudflare  as well as Amazon   cost-benefit in using DLTs is somewhat ameliorat-
                          224
                                        225
            Cloud Services.                                    ed by the need to trust permissioned authors rather

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