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October 2022
- 11 participants
- 365 discussions
Donald Trump seems pretty unhappy about the newly approved wind project off Martha’s Vineyard
by Gunnar Larson 19 Oct '22
by Gunnar Larson 19 Oct '22
19 Oct '22
19 Oct '22
"Trump adviser involved in Vineyard Wind opposition"
https://www.eenews.net/articles/trump-adviser-involved-in-vineyard-wind-opp…
David Stevenson, policy director at the Caesar Rodney Institute,
participates in a press conference yesterday in Boston announcing a lawsuit
that aims to block construction of Vineyard Wind, the first major offshore
wind facility approved in the United States. AP Photo/Philip Marcelo
The two Nantucket women said they were suing the federal government because
they wanted to save the North Atlantic right whale from offshore wind. Then
a former member of President Trump’s EPA transition team stepped to the
microphone to commend them for their bravery.
“They did it voluntarily,” David Stevenson, the former Trump adviser, said
of the women. “They’re not getting anything out of this other than trying
to save the whales, save Nantucket.”
So went a press conference outside the Massachusetts State House yesterday,
where offshore wind critics announced a lawsuit challenging the federal
government’s approval of Vineyard Wind, the first major offshore wind
project in America to be issued an environmental permit.
Advertisement
The lawsuit marks a new chapter in a decadeslong push to build offshore
wind farms in America. Cape Wind, the first offshore wind project proposed
in the U.S. waters, was sunk by nearly two decades of legal battles. Now,
the question is whether they will sink a second generation of projects.
Vineyard Wind, a 62-turbine project 12 miles south of Martha’s Vineyard, is
the first to run the legal gauntlet. The $2.8 billion project is the only
utility-scale offshore wind project to receive a final permit from the
Bureau of Ocean Energy Management. Other projects could soon follow. BOEM,
as the bureau is known, has committed to reviewing 16 others along the
Eastern Seaboard by the end of President Biden’s first term.
The lawsuit
<https://subscriber.politicopro.com/f/eenews/?id=0000017b-7fbb-d1d1-a57f-ffb…>
filed
by Nantucket Residents Against Turbines in the U.S. District Court District
of Massachusetts argues that the bureau failed to consider the impact of
Vineyard Wind on right whales. It seeks to vacate the permit.
It’s not the first time opponents have challenged BOEM’s review of Vineyard
Wind. That distinction belongs to a small-scale solar developer who owns a
vacation house on Martha’s Vineyard (*Climatewire
<https://subscriber.politicopro.com/article/eenews/2021/07/20/solar-executiv…>*,
July 20).
But the Nantucket suit illustrates how critics of offshore wind are
starting to organize in opposition to projects along the East Coast.
Nantucket Residents Against Turbines is a part of the American Coalition
for Ocean Protection, a network of community groups that are fighting
offshore wind developments, Stevenson said.
The Caesar Rodney Institute, a libertarian think tank where Stevenson
serves as director of the Center for Energy and the Environment
<https://www.caesarrodney.org/CRI-staff/David-T-Stevenson.htm>, is
spearheading a legal defense fund to fight offshore wind up and down the
Eastern Seaboard.
“We communicate with each other, help each other out with resources and
ideas,” he said. “You’ve got the emotional power of the beach community,
that comes without a lot of background in how to get things done, with
these state policy groups.”
Community groups like Nantucket Residents Against Turbines played a key
role in defeating Cape Wind. At the time, the Alliance to Protect Nantucket
Sound unleashed a storm of legal action against Cape Wind with funding from
conservative industrialists like William Koch.
Stevenson said donations to the American Coalition for Ocean Protection
have come from individual property owners along the coast, though he
declined to identify any.
“So far there is no Koch money, not that we wouldn’t take it,” he said.
The Caesar Rodney Institute recently helped establish a legal defense fund
to finance lawsuits against offshore wind projects. It has raised $75,000
to date with the goal of raising $500,000, Stevenson said. He said the
money would be directed to plaintiffs with standing and a strong legal
case. None has yet gone to Nantucket Residents Against Turbines.
But the lawsuit sets an important precedent, Stevenson said.
“The approval of the Vineyard Wind is kind of a hinge point,” he said. “If
it gets approved and it stands with the shoddy job they did on the EIS
[environmental impact statement], they’ll approve the rest of them. The
coalition partners agree we need to stop the Vineyard Wind project.”
Whale extinction ‘inevitable’
Vallorie Oliver, the founder of Nantucket Residents Against Turbines, is
listed as the sole plaintiff in the case.
BOEM had failed to provide scientific justification for giving Vineyard
Wind an incidental take permit for right whales, Oliver told reporters at
the press conference. The permit enables the developer to drive monopoles
into the seabed in the vicinity of up to 20 whales. Noise from pile driving
is considered harassment.
A biological assessment
<https://subscriber.politicopro.com/f/eenews/?id=0000017b-7fbc-d290-a57b-fff…>
conducted
by NOAA Fisheries as part of BOEM’s analysis found pile driving activity
could temporarily force right whales to go elsewhere, but was unlikely to
injure or kill them.
“Once these installations are erected and the damage is done, that is not
the time for regret, especially for the North Atlantic right whale, whose
extinction will then most surely be inevitable,” Oliver said.
Right whales and offshore wind projects have the potential to come into
conflict. A recent study
<https://www.int-res.com/articles/esr2021/45/n045p251.pdf> by the New
England Aquarium found the whales’ presence appears to be increasing in the
waters off southern New England, where seven wind developments have been
proposed.
Whale sightings were common between 2011 and 2015 just north of the area
where Vineyard Wind and six other developments have been proposed, the
study found. They moved into the eastern area of the wind development area
in the winters of 2017 to 2019.
The whales were even more prevalent during the spring months.
“Implementing mitigation procedures in coordination with these findings
will be crucial in lessening the potential impacts on right whales from
construction noise, increased vessel traffic, and habitat disruption in
this region,” the aquarium researchers wrote.
Funding for the aquarium study was provided by BOEM and the Massachusetts
Clean Energy Center, a state entity that supports the build-out of
renewable energy in the Bay State.
BOEM and Vineyard Wind declined comment on the lawsuit.
‘No … serious injury of any kind’
The developer, a joint venture of Avangrid Inc. and Copenhagen
Infrastructure Partners, has made efforts to limit its impact on whales.
In 2019, Vineyard Wind agreed to a series of voluntary mitigation measures
as part of a deal <https://www.vineyardwind.com/protecting-environment> with
the Natural Resources Defense Council, National Wildlife Federation and
Conservation Law Foundation. The deal calls for no pile driving between
Jan. 1 and April 30 and requires the developer to halt pile driving if
whales are sighted near the area at other times of the year.
Those conditions were incorporated into BOEM’s permit.
The biological assessment issued by NOAA Fisheries found that pile-driving
events would last up to three hours, but would be unlikely to harm the
animal if whales went undetected.
“No non-auditory injury, serious injury of any kind, or mortality is
anticipated,” the opinion stated.
Fishing gear, which can entangle whales and kill them, and vessel strikes
are the primary cause for the dangerous drop in the right whale population
over the last decade, the New England Aquarium found. It estimated the
whale’s total population is 356.
NOAA, which regulates commercial fisheries, is reportedly weighing more
stringent regulations on fishing gear in an attempt to stop the decline of
right whales.
While offshore wind critics said they were concerned about Vineyard Wind’s
impact on right whales, they said they were not following the NOAA proposal
and could not offer an opinion on what it would mean for the animal.
“The fishermen say they are already obeying all the restrictions,”
Stevenson said.
‘I am not a denier’
Stevenson made a name for himself in conservative circles for fighting
proposed climate policies. He has opposed Pennsylvania’s decision to join
the Regional Greenhouse Gas Initiative, a cap and trade program for power
plants, and is on the board of policy advisers
<https://www.heartland.org/about-us/who-we-are/david-t-stevenson> at the
Heritage Institute, a conservative think tank that has questioned the
science of climate change (*Energywire*
<https://subscriber.politicopro.com/article/eenews/2020/02/18/pas-future-in-…>,
Feb. 18, 2020).
At EPA, Stevenson was a part of a transition team that sought agency
records on controversies like “Climate Gate,” the 2009 hacking of the
University of East Anglia’s Climate Research Unit that some conservatives
argued showed climate change was a conspiracy cooked up by scientists
(*Greenwire
<https://subscriber.politicopro.com/article/eenews/2017/09/25/trump-transiti…>*,
Sept. 25, 2017). In one instance, Stevenson specifically requested agency
communications regarding EPA’s crafting of a 2013 social cost of carbon
calculation.
Stevenson said his opposition to offshore wind was borne from a belief that
it would damage the environment and economy, causing electricity bills to
rise.
“I am not a denier of climate change. I am not against solar,” Stevenson
said, noting he has built a net-zero house in Delaware and was involved in
solar research when employed by DuPont, a chemical company.
Massachusetts and other Northeastern states involved in offshore wind
should consider solar and natural gas as alternatives, he said.
Members of Nantucket Residents Against Turbines said they were grateful for
the support.
Raising concern about Vineyard Wind’s impact on Nantucket has often been a
lonely task, said Mary Chalke, a member of the group who joined Stevenson
and Oliver at yesterday’s press conference. Many people on Nantucket were
unaware of the project and often confused it for Cape Wind.
She described Nantucket Residents Against Turbines as “pure grassroots” and
said environmental impacts like the plight of the right whale are its
primary concern.
“Politics or other special interests don’t weigh into that as far as I am
concerned,” she said. To the contrary, support from other communities along
the East Coast and groups like the American Ocean Protection Coalition was
welcome.
“We’re not alone anymore,” Chalke said.
1
0
19 Oct '22
https://www.eenews.net/articles/bernhardt-trump-tried-to-boost-offshore-win…
Where is Elizabeth Warren on the United States' largest wind farm off
the coast of Massachusetts?
JPMorgan is clearly subject to the Endangered Species Act yet Mr. Trump's
role in Vineyard Wind seems being ignored.
Bernhardt: Trump tried to boost offshore wind, not kill it
By *Benjamin Storrow* | 07/21/2021 06:46 AM EDT
[image: David Bernhardt and Donald Trump.]
Then-Interior Secretary David Bernhardt spoke last year as President Trump
looked on. Bernhardt yesterday defended his role in delaying a major
offshore wind farm. Drew Angerer/Getty Images
Former Interior Secretary David Bernhardt defended the Trump
administration’s lengthy review of America’s first offshore wind farm in an
interview yesterday, saying the additional environmental analysis he
ordered was intended to strengthen the project against legal challenges
rather than kill it.
The Trump administration had initially planned to complete a review of
Vineyard Wind in the summer of 2019. But Bernhardt surprised the project’s
developers, who proposed a $2.8 billion wind farm near Martha’s Vineyard,
Mass., by expanding a government study of the project to consider other
wind farms proposed along the East Coast.
The announcement cast a pall over the wind industry. It slowed planning
work on other projects and raised questions about the viability of offshore
wind in the United States. Many industry supporters suspected the move was
a reflection of former President Trump’s disdain for wind power, which he
regularly lambasted as an eyesore and a danger to birds. Trump erroneously
claimed wind turbines could cause cancer.
But in a phone interview yesterday while vacationing at a North Carolina
beach, Bernhardt said it was “fundamentally false” that the administration
was playing politics with Vineyard Wind. Instead, he said his call for more
analysis was driven by the growing number of wind projects proposed along
the East Coast and by divisions among federal agencies over Vineyard Wind’s
potential impact on commercial fishing and marine navigation.
“You can’t proceed with federal agencies warring with each other,” he said.
“I was like, ‘Look, we don’t have our ducks in a row.’”
He added, “The last thing we wanted to do is put out a finalized program
that wasn’t legally sustainable.”
Bernhardt’s comments came hours after the Bureau of Ocean Energy Management
released more than 500 pages of documents in response to a Freedom of
Information Act request by E&E News. The documents were related to the
permitting process of Vineyard Wind.
They show that BOEM officials were nearing completion of the project’s
environmental impact statement in the summer of 2019. It was the final step
before approval.
Then Bernhardt got involved.
“BOEM briefed the DOI Executive review team on the Vineyard Wind Final EIS
on Friday, June 28th (this briefing is required prior to publication of a
Final EIS for all DOI agencies),” Brian Krevor, an environmental protection
specialist at BOEM, wrote to other federal officials involved in the permit
review on July 1, 2019.
“The Secretary of the Interior is now personally reviewing the Final EIS
and associated materials,” he added. “As a result, the Final EIS was not
filed with the EPA on the 28th and will not be published on July 5th. I
currently do not have a date for when the document will be published.”
Bernhardt said he had promised Massachusetts Gov. Charlie Baker, a
Republican who has championed offshore wind, that he would personally read
Vineyard Wind’s EIS. He said he was “extremely troubled” by what he read.
A growing number of states along the East Coast had signed contracts to buy
electricity from offshore wind projects by the time Interior officials were
finalizing the Vineyard Wind study. But the cumulative impact of those
projects on other ocean users like the fishing industry was not considered
in the study, Bernhardt said yesterday.
He was also concerned about issues raised by other agencies. NOAA
Fisheries, a division of the Commerce Department that oversees federal
fisheries, had informed BOEM it did not agree with the bureau’s impact
analysis of Vineyard Wind. The U.S. Coast Guard had raised separate issues
about the safety of marine vessels transiting the project’s towers.
“It was very important to me that we not have conflict between the agencies
when you go out for the first project,” Bernhardt said. “People have to
have faith the government is doing the job it is required to do and
managing the varying interests we had. We couldn’t be shooting at each
other.”
Trump critics saw the delay as an attempt to kill the project, but
Bernhardt said he has a long-standing interest in offshore wind. In 2005,
he helped draft the Energy Policy Act as Interior’s congressional liaison.
The law gave Interior oversight of offshore wind permitting.
“I think where I depart from perhaps some is that because I was actually
involved in the development of the legislation, it is my view that a high
bar was set in the standards that the secretary must meet to move forward
both in preventing waste but also in protecting other uses,” Bernhardt said.
“I think the legislation that was created was intended to be cautionary. It
is important to make these projects work in areas and places where they
don’t do harm to others,” he said. “That was what Congress was trying to
do, because it was developed in context of the Cape Wind situation.”
Cape Wind was a 130-turbine project proposed in Nantucket Sound. The
federal government lacked regulations for permitting offshore wind projects
when it was initially proposed. It was ultimately abandoned in 2017 after
years of lawsuits from residents who worried about the sight of turbines
and their impact on environmental and cultural resources.
Fearing a similar outcome, Vineyard Wind went back to the drawing board
after Bernhardt’s unexpected announcement in 2019.
It revamped the layout of its project, agreeing to space its turbines 1
nautical mile apart in a grid. The move was intended to address concerns
from fishermen and the Coast Guard about transiting between the turbines.
Other offshore wind developers said they would follow the same pattern.
Vineyard Wind also increased the size of its turbines, from 9.5 megawatts
to 12 megawatts, enabling it to reduce the number of towers from 84 to 62.
The company’s initial plan called for 104 turbines. The project has a
capacity of 800 MW, enough to power 400,000 homes.
When BOEM released a draft review of the cumulative impact of all proposed
offshore wind projects in the summer of 2020, it found the industry would
have an adverse effect on fishermen. But it also concluded that fishermen
would be affected by climate change and that the burden of the turbine
would be concentrated on different parts of the fishing fleet. Squid boats,
it found, would be most impacted by Vineyard Wind. It also determined that
the wind industry stood to create thousands of jobs.
BOEM subsequently missed a November deadline to finish its review. Instead,
it would announce its final decision on Jan. 15, five days before Trump was
scheduled to leave office. In response, Vineyard Wind announced in December
that it was withdrawing its permit application, saying it needed to
consider the impact of using larger turbines as part of the project.
It quickly refiled its application after Biden took office, concluding the
larger turbines did not alter the project’s impact. BOEM approved a final
EIS in March and stamped Vineyard Wind’s permit in May. The final decision
said it expected the project would have a negligible to moderate impact on
fishermen but that the impact could become major as a result of future
offshore projects. A 2020 study by the Coast Guard concluded that the
updated grid layout addressed many of the navigation concerns.
But the permitting snafu may yet plague the project.
A lawsuit filed this week challenging the project’s permit said BOEM erred
when it decided to re-accept the application without considering the impact
of the larger turbines.
Bernhardt, for his part, said Interior was committed to finishing its
review under his watch, saying a tremendous amount of work was done to
“ensure that when this program went forward it would be defensible and
stand the test of time.”
“A tremendous amount of work on this project was happening up to the moment
they chose to terminate,” he added.
Asked if the final EIS released by the Biden administration differed from
the one being prepared by the Trump administration, Bernhardt said it was
difficult to evaluate because his team never finished its review.
But, he added, “I would be very skeptical that it looks dramatically
different.”
1
0
Jennifer Robinson is to Journalist Julian Assmange what Clavin Ayre is to Pastor Craig Wright.
by professor rat 19 Oct '22
by professor rat 19 Oct '22
19 Oct '22
See, Austria got all the criminals - Amerikkka got all the Gilead Puritans.
Here endeth the History lesson.
1
0
xNY.io - Bank.org | DOJ Memo #4 - Goldman Sachs Deferred Prosecution Agreement
by Gunnar Larson 19 Oct '22
by Gunnar Larson 19 Oct '22
19 Oct '22
https://drive.google.com/file/d/1pwysH05O9rlrFVs_w1Jq3EiQdBoktCtt/view?usp=…
March 10, 2022
BY ELECTRONIC MAIL
Mr. John Marzulli
United States Department of Justice
Eastern District of New York
271 Cadman Plaza East
Brooklyn New York, 11201
John.Marzulli(a)usdoj.gov
Re: Memo #4 - Goldman Sachs Deferred Prosecution Agreement
Dear Mr. Marzulli:
The Department of Justice has yet to respond to Memo #1, Memo #2 and Memo
#3 with our recent inquiry to the 1Malaysia Development Berhad Deferred
Agreement. Goldman Sachs' Deferred Prosecution Agreement
<https://www.justice.gov/usao-edny/pr/goldman-sachs-resolves-foreign-bribery…>
with the United States of America is in potential breach, with ethical
enforcement being concerned.
Memo #4 aims to associate the malfeasance in Malaysia with war crimes of
aggression (in the planning, initiation, or execution of a large-scale and
serious act of aggression), leveraging the world’s only military divided
capital city Nicosia, Cyprus.
1.
Additionally, Memo #4 aims to earn the DOJ’s assessment of New York
State’s regulatory marketplace manipulation deriving the war crime against
peace, related to the planning, preparation, initiation, waging or
participation in a common plan or conspiracy related to a war of
aggression, which can only apply in relation to international armed
conflict.
2.
In this case, the first challenge is to observe and consider the simple
idea that the DOJ’s Deferred Prosecution Agreement with Goldman Sachs
alone, through means of regulatory arbitrage naively fails to recognize the
‘cause and effect’ relationship at play at the inception of Memo #4’s
assertion of war crimes.
3.
Even with the best of intentions, perhaps unknowingly the DOJ may be
amplifying the effect of potential war crimes by indirectly supplementing
the root cause of the problem and financial model of the Deferred Agreement
being self-policing.
Mr. Marzulli, there has been an active United Nations peacekeeping mission
in Cyprus since the 1964 Turkish military invasion and occupation of the
northern third of Cyprus. Only Turkey recognises the Turkish Republic of
Northern Cyprus, while there is broad recognition that the ongoing military
presence constitutes occupation of territories that are under Turkish
military control.
-
The graduate education behind Memo #4 is a product of the University of
Nicosia’s (UNIC) main campus, located adjacent to the United Nations Buffer
Zone that separates the invaded Turkish Republic of North Cyprus and the
Republic of Cyprus, which joined the European Union in 2004.
-
Memo #4 is also a product of United Nations consultancy, based at its
Manhattan headquarters, where (today, what is now xNY.io - Bank.org)
was credited with increasing the breadth and accessibility of reference
content from the world’s most important multinational organization.
-
Memo #4’s subject of war crimes has preeminent association with such
projects as the Audio Visual Library of International Law.
Over the following sections, Memo #4 will provide a detailed timeline that
would constitute real concern of the war crime of aggression yielding the
war crime against peace in active war conflict in the world’s only military
divided capital, funded from Manhattan Island.
The Bank of Cyprus and Illegal Short Selling Irregularities of Turkey’s
Markets
Mr. Marzulli, turn this matter as we will, and look at it from any side
whatsoever, and it presents the appearance of a cross-border act of
aggression. Goldman Sachs’ potential disrespect to the Deferred Agreement’s
core values has cultivated new crimes that aim to manipulate cross-border
war crime regulatory frameworks.
-
On April 02, 2021 the Financial Times reported that Turkey fined Goldman
Sachs over alleged irregularities in short selling, just a week after
foreign investors pulled $1.9B from the country’s stock and bond markets.
Turkey’s Capital Markets Board said that Goldman Sachs was among 10
securities firms that had placed orders for short selling without proper
notification, violating rules enacted previously that temporarily
prohibited such transactions.
-
On April 20, 2021 the CyprusMail (Cyprus’ only English Language daily
newspaper) reported Goldman Sachs International acted as Global
Coordinators and Dealer Managers in a $330M bond issuance for the Bank of
Cyprus.
Given the active military conflict in Cyprus, Memo #4 notes that there is
one place on the planet you are not supposed to do this sort of thing.
Furthermore, the DOJ’s Deferred Agreement with Goldman Sachs may have been
tainted with the potential war crime of aggression, risking international
peace and the lives of United Nations peacekeepers, while jeopardizing the
United States of America’s financial security.
Concern of New York Prime Bank Instrument Fraud and Marketplace Manipulation
The United States Department of the Treasury warns that Prime Bank
Instrument Fraud schemes have attracted significant international
attention, since individuals and organizations have lost billions of
dollars worldwide. "Prime Bank Instrument Fraud" is the general term given
to prime bank fraud schemes that go by many different names.
During April 2021, Goldman Sachs could not in good faith (and, plausible
deniability) make any reasonable claim of holding a pristine relationship
with Turkey’s Central Bank or with Cyprus’ largest financial institutions,
given the 1Malaysia Development Berhad scandal and then pending Deferred
Prosecution Agreement with the United States of America.
-
Memo #4 suggests that Goldman Sachs developed a Prime Bank Instrument
Fraud program to level out yo-yo market dynamics caused by failed
marketplace manipulation exercises in Turkey and Cyprus.
-
Systematic bank fraud and/or marketplace manipulation of any kind
between Turkey and Cyprus could constitute the war crime of aggression.
-
Furthermore, Memo #4 argues that Goldman Sachs may have tried to
bambooze governments in New York, Cyprus and Turkey through regulatory
arbitrage loopholes, while Goldman seemingly may have not considered the
totality of such actions as war crimes.
Turkey has the highest inflation in Europe. It has the second-highest rate
of inflation among emerging markets, just behind Argentina. It has the 13th
highest inflation rate in the world, ranking it between South Sudan and
Nigeria. After Goldman Sachs was fined for illegal stock and bond market
short selling by the Turkish government, logic would argue further
malfeasance potentially could have been avoided by the DOJ’s 1Malaysia
Development Berhad investigation.
-
On April 15, 2021 CNBC reported that Goldman Sachs (note, the previous
section’s milestones of April 02, 2021 and April 20, 2021) crucially
removed its bias toward Turkey tightening interest rates. Goldman issued
guidance highlighting the fact that the bank thought that, “…the removal of
the tightening bias against rising inflation expectations suggests that the
TCMB (Turkish Central Bank) now has a more dovish reaction function.”
-
On August 14, 2021 the CyprusMail reported serious concern among
economists about data reporting from the Turkish Statistical Institute.
Ahmet Takan, a former official with the office of the Turkish prime
minister, acted as a whistle blower, warning that Turkey potentially was
manipulating inflation data.
-
On September 1, 2021 Reuters reported that Goldman Sachs hiked Turkish
growth forecasts. Goldman economists issued guidance stating, "Overall, the
Turkish economy has been able to grow faster than we thought without a
deterioration in its external balances, as the pickup in foreign demand has
been very supportive."
-
On November 30, 2021 Reuters reported that Goldman Sachs trimed Turkey’s
2022 growth forecast. Goldman Sachs' Murat Unur stated, "We think that the
GDP figures released today tell us little about the pace of economic
activity going forward as the recent sell-off in the Lira is likely to
impact economic activity significantly"
Mr. Marzulli, the DOJ’s Deferred Prosecution Agreement with Goldman Sachs
was signed on October 21, 2021. The timeline of events above do not
coincide with terms and conditions of the Deferred Agreement mandated by
the United States of America.
Furthermore, as an international graduate scholars of the world’s only
military divided capital on the planet, xNY.io - Bank.org should be
protected from any association of crimes against peace, related to the
planning, preparation, initiation, waging or participation in a common plan
or conspiracy related to a war of aggression, which can only apply in
relation to international armed conflict.
War Crimes Against Humanity
Mr. Marzulli, xNY.io - Bank.org is concerned that potential breaches to the
Deferred Agreement are impacting our global enterprise. Crimes against
humanity can be committed in peacetime as well as during an armed conflict.
Even a single act could fall under this exclusion ground provided it forms
part of a widespread or systematic attack against a civilian population and
the act is committed by any person (including a civilian) who had knowledge
of the attack and the link of the act to the attack.
1.
We are looking to learn more about the DOJ’s approach to assessing any
potential breaches to the Deferred Agreement’s mandates as we determine New
York State’s role in cross-border bank regulation and corresponding
innovation beyond war crimes against humanity.
2.
In order to establish whether a war crime or a crime against humanity
has been committed, the case officer should consult the relevant
international instruments and case law.
3.
Crimes against humanity are fundamentally inhumane acts, committed as
part of a systematic or widespread attack. Inhumane acts, which could reach
this threshold when committed pursuant to or in furtherance of a State or
organizational policy (potentially, New York State bank regulation).
4.
Persecution against any identifiable group or collectivity on political,
racial, national, ethnic, cultural, religious, gender, or other grounds
that are universally recognised as impermissible under international law.
5.
Furthermore, we have made 28 highlights to the Deferred Agreement
providing supporting reference to Memo #4’s overarching premise.
xNY.io - Bank.org submits Memo #4 for DOJ consideration of other inhumane
acts of a similar character intentionally causing great suffering, or
serious injury to body or to mental or physical health. Some crimes against
humanity would require an additional specific intent, such as Goldman Sachs
willfully disrespecting New York State and/or overall peace and security of
the United States of America.
Memo #1, Memo #2, Memo #3 and Memo #4 outline instances that correspond
with the associated definitions of the potential war crimes abroad and
jeopardize the future of bank innovation from New York, at great sacrifice
to the Homeland.
We hope to learn the DOJ’s approach to comment on Memo #4’s subject matter
or, without delay refer these concerns to the International Criminal Court
and/or International Court of Justice for comment.
Respectfully yours with anticipation,
Gunnar Larson - xNY.io <http://www.xny.io> | Bank.org
<http://bank.org>MSc
<https://www.unic.ac.cy/blockchain/msc-digital-currency/?utm_source=Google&u…>
- Digital Currency
MBA
<https://www.unic.ac.cy/business-administration-entrepreneurship-and-innovat…>
- Entrepreneurship and Innovation (ip)
G(a)xNY.io +1-646-454-9107
1
10
140 Highlights to Complaint by Former Governor Andrew M. Cuomo Against Attorney General Letitia Ann James, Joon Kim, Esq., and Anne Clark, Esq.
by Gunnar Larson 19 Oct '22
by Gunnar Larson 19 Oct '22
19 Oct '22
Brody Larson collates 140 highlights to Complaint by Former Governor Andrew
M. Cuomo Against Attorney General Letitia Ann James, Joon Kim, Esq., and
Anne Clark, Esq.:
https://drive.google.com/file/d/1EOzEmOpxCBNfThWYqPPDaV0evqGFVFTd/view?usp=…
"I am the 56th Governor of the State of New York and write to bring to the
Attorney
Grievance Committee’s (“Committee”)attention certain professional
misconduct by New York Attorney General LetitiaAnn James (“AGJames” or the
“Attorney General”), and two Special
Deputies to the First Deputy Attorney General appointed by AG James, Joon
Kim, Esq., and Anne Clark, Esq., to assist in an investigationof
allegations of sexual harassment against me."
1
1
158 highlights to DONALD J. TRUMP, vs. HILLARY R. CLINTON.
Honestly, I understand the FBI's scenario here. Why on god's green Earth
would New York be used and abused while at the expense of innovation.
DONALD J. TRUMP, vs. HILLARY R. CLINTON:
https://drive.google.com/file/d/1zggK7lgptlZ6Qn11EndzbDloqqVxRifv/view?usp=…
1
7
xNY.io - Bank.org | Memo #2 - JPMorgan Chase Board of Directors ESG Marketplace Manipulation
by Gunnar Larson 18 Oct '22
by Gunnar Larson 18 Oct '22
18 Oct '22
https://docs.google.com/document/d/1bxERzXknAFfVW3YsDpNB-GPlVoiLAeeBXUrxwOF…
May 1, 2022
BY ELECTRONIC MAIL
Investor Relations
Board of Directors, JPMorgan Chase & Co.
277 Park Avenue
New York, NY 10172-0003
JPMCinvestorrelations(a)jpmchase.com
Re: JPMorgan Chase Board of Directors ESG Marketplace Manipulation
Dear Board of Directors:
xNY.io - Bank.org recently contacted JPMorgan Chase’s board of directors to
communicate our concern(s) that potentially JPMorgan Chase may be engaging
in exploitation of more than $100B of ESG asset liabilities, across
international regulatory arbitrage structures, while headquartered in
Manhattan. Specifically, the duty to promote the success of the company is
that a director must act in the way that she considers, in good faith, and
would be most likely to promote the success of the company for the benefit
of its members as a whole.
-
Failure by a board to adequately consider ESG-related risks,
particularly entity-specific compliance risks such as breach of securities
laws, could serve as the basis for liability of individual directors or
officers for breach of their fiduciary duties.
Given JPMorgan’s five cout felonies, xNY.io - Bank.org is concerned with
your board of director governance in preventing ESG fraud. xNY.io -
Bank.org’s assessment of JPMorgan’s board embraces fundamentals including
liquidity risk and protecting New York ESG cross border innovation from
marketplace manipulation.
-
According to JPMorgan’s August 2021 Sovereigns and ESG whitepaper, the
bank states that governance carries the largest weight of the three ESG
pillars across scores, as it is the most empirically relevant for asset
prices.
-
JPMorgan notes that philosophically, the bank views good governance as a
foundational pillar for positive ESG developments in other pillars.
Today’s memo follows protocol suggested by the United States of America, in
that JPMorgan Chase’s board of directors is responsible to xNY.io -
Bank.org’s enterprise and the Department of the Interior, in connection
with any action alleging a violation of the Endangered Species Act, by any
person (“person” means an individual, corporation, partnership, trust,
association, or any other private entity) claiming the benefit of any
exemption or permit under the Act, who shall have the burden of proving
that the exemption or permit is applicable, or has been granted, and was
valid and in force at the time of alleged violation.
xNY.io - Bank.org has made 91 highlights to the Department of Interior’s
Endangered Species Act for JPMorgan Chase’s board of directors reference.
1.
xNY.io - Bank.org has reason to believe in the JPMorgan Chase board of
directors’ engagement of ESG marketplace manipulation, risking your ESG
portfolio’s future at the cost of New York digital asset innovation.
2.
xNY.io - Bank.org references your 2021 Environmental Social and
Governance Report, totaling $117B of ESG “development funding”
transferred from New York to Caribbean and Eastern European accounts.
3.
xNY.io - Bank.org is concerned of JPMorgan Chase board directors
leveraged marketplace manipulation techniques in allocating ESG funds to
engage in potential harassment (the term "harassment" means any act of
pursuit, torment, or annoyance) of some of the world’s most precious
endangered species protected by domestic and international governance.
4.
JPMorgan Chase’s $2.3B ESG “wind farm” facility is characterized by the
Washington Post as a potential misuse of ESG assets (and board policies)
to fund probable violation(s) of the Marine Mammal Protection Act of 1972.
Looking internationally, xNY.io - Bank.org is concerned of further ESG
marketplace manipulation structures, sacrificing endangered species, via
JPMorgan Chase’s board directed ESG investments in the Caribbean (your
largest ESG investment region). xNY.io - Bank.org signals that JPMorgan’s
board of directors is party to the Convention on Nature Protection and Wild
Life Preservation in the Western Hemisphere.
Being clear, any violation of the Endangered Species Act, the Marine Mammal
Protection Act and/or the Convention on Nature Protection and Wild Life
Preservation in the Western Hemisphere … Requires xNY.io - Bank.org to
consult JPMorgan Chase board members on ESG allocations that may be in
conflict with construction, or other development projects, or other forms
of economic activity.
xNY.io - Bank.org asks JPMorgan Chase board directors to return the
Secretary of Department of the Interior’s approval, confirming licensing
and/or exclusion to the Endangered Species Act, with further authorization
of “harassment” pursuant to exemption(s). Including (if available) a
similar Environmental Protection Agency permit that is applicable and is
valid and in force.
-
Due to the riskiness of ESG portfolio mismanagement in violation of the
Endangered Species Act, ESG marketplace manipulation risk(s) may trigger
causal shocks to New York State monetary and regulatory innovation.
-
According to JPMorgan’s sovereign fund ESG research, “A common complaint
about ESG analysis is that data can be difficult to source. Some sovereign
data is in fact more readily available than corporate data given the
multitude of multinational organizations and NGOs – including the World
Bank, the IMF and the United Nations.”
-
The European Central Bank provides support to the eurozone sovereign
debt market but has more restrictions on what and how much it can buy, so
eurozone bonds can trade with more credit risk premium compared to other
major developed market bonds.
-
Whatever the case may be, JPMorgan disclosures detail significant
concern of lapse in board governance and ESG portfolio risk with potential
violation of the Endangered Species Act, risking ESG portfolio default(s)
in Europe and the United States risking ESG customer financial abuse.
Forbes recently profiles JPMorgan Chase ESG investments as problematic,
highlighting that your board of directors potentially are allocating ESG
proceeds in competition with human rights at the expense of customers’ best
interests while investing heavily in fossil fuels. A letter to JPMorgan
Chase’s board of directors from ESG scholars (including, The Sierra Club,
Public Citizen, Greenpeace, Amazon Watch, Revolving Door Project,
Rainforest Action Network and the Center for International Environmental
Law) suggests the bank would “...lock us into energy sources that are
overly expensive and subject to wild price swings, and that exacerbate
rather than ease global conflict.”
xNY.io - Bank.org aims to protect ESG digital asset innovation and
JPMorgan’s board should understand your proprietary ESG scoring matrix
should signal seismic marketplace manipulation risk if directors are in
potential violation of any Endangered Species Act covenant.
-
Head of Europe, Middle East, and Africa (EMEA) distribution at JP Morgan
Asset Management says, “In Europe, we do not have a semi-transparent
product – like the US and Australia – which would add further complexity to
the trading. For example, the US has several models which make it harder
for the AP to guess what the actual fund looks like and therefore the costs
might be higher accordingly.”
-
Given, JPMorgan may potentially be in breach of United States Endangered
Species Act provisions, similar risk of ESG asset failure(s) may include
Europe, Middle East, Africa and Australia international law, as ratified by
the Convention on International Trade in Endangered Species of Wild Fauna
and Flora.
While directors and officers are likely to be particularly focused on the
risk that they may be found personally liable for a breach of their duties,
proper ESG compliance with fiduciary obligations requires acting to a
higher standard. Given the defenses available to fiduciaries, and the
difficulty in bringing claims for breach of fiduciary duty, a director or
officer found to be liable for such ESG breaches will generally have acted
egregiously. This ‘sliding scale’ of the standards to which directors and
officers should adhere.
Following the Endangered Species Act, xNY.io - Bank.org kindly petitions
JPMorgan’s board of directors, in connection with all ESG investments,
claiming the benefit of any exemption or permit under the United States
Department of the Interior’s Endangered Species Act … Shall have the
burden of proving that an exemption or permit is applicable, or has been
granted, and is valid and in force.
-
At JPMorgan’s earliest convenience (within 60 days of receipt of this
memo) xNY.io - Bank.org kindly requests a certified copy of JPMorgan
Chase’s approval by the Department of the Interior, being a license and/or
exclusion to the Endangered Species Act and/or the Marine Mammal Protection
Act.
-
JPMorgan Chase suggests a commitment to anti-corruption compliance is
central to the success of its business. Your board of directors stand to
maintain that trust by promoting a corporate culture that encourages
ethical business practices and compliance with both the letter and the
spirit of the laws of the countries in which the JPMorgan conducts business.
xNY.io - Bank.org’s research guidance from the United States Securities and
Exchange Commision, supports the international community in taking actions
to address ESG issues on a global basis, and those actions that can have a
material impact on companies.
Future correspondence concerning ESG innovation is at your board’s leisure.
Respectfully yours with appreciation,
Gunnar Larson | xNY.io <http://www.xny.io> - Bank.org <http://bank.org>, PBC
MSc
<https://www.unic.ac.cy/blockchain/msc-digital-currency/?utm_source=Google&u…>
- Digital Currency
MBA
<https://www.unic.ac.cy/business-administration-entrepreneurship-and-innovat…>
- Entrepreneurship and Innovation (ip)
G(a)xNY.io +1-646-454-9107
1
1
18 Oct '22
2022-092267: “Dear Madam or Sir: On May 18, 2022 xNY.io - Bank.org received
a copy of a financial disclosure form for Mr. Richard Weber (General
Counsel, NY-DFS) noting an advisory council role at the Las Vegas Museum of
Organized Crime and Law Enforcement.
No address
was provided:
https://drive.google.com/file/d/1CCIh9CQiwxVILSv86B54kEcipVRnx1YQ/view?usp=…
We would like to receive any and all records NY-DFS and Human Rights hold
for this appointment approval for a state associated represenative.
Warm regards,
Gunnar
Gunnar Larson
xNY.io - Bank.org
646-454-9107
Expected due date: 10.18.22.
---------- Forwarded message ---------
From: <Carmen.Garrett(a)dfs.ny.gov>
Date: Tue, Oct 18, 2022, 11:13 AM
Subject: Your Freedom of Information Law Request FOIL-2022-092267-018305
To: <G(a)xny.io>
Good Morning:
Attached, please find correspondence from the New York State Department of
Financial Services pertaining to your FOIL request.
Thank you.
Tracking Number:FOIL-2022-092267-018305
1
1
“We’ve got to change the cost-benefit calculus of criminals and
nation-states who believe they can compromise U.S. networks, steal U.S.
financial and intellectual property, and hold our critical infrastructure
at risk, all without incurring any risk themselves...” (Wray 2020)
<https://sciwheel.com/work/citation?ids=10936531&pre=&suf=&sa=0>.
What organizational HR management techniques are required for an enterprise
to actively convince hundreds, if not thousands, of employees, clients and
customers to pursue their strategy while knowing it was fatally flawed?
--------
xNY.io
CRYPTOBANK
Table of Contents
Introduction 2 <https://docs.google.com/document#heading=h.qw9a2wl4q92s>
Focus, Goals and Objective(s) 3
<https://docs.google.com/document#heading=h.c0rh86mvw9ua>
Strategic Intent 4
<https://docs.google.com/document#heading=h.kuxwgdwni6p4>
Innovation Strategy 5
<https://docs.google.com/document#heading=h.7ueepdr7oduo>
Pioneering Human Resources (HR) Management in Banking 6
<https://docs.google.com/document#heading=h.c2qklq4en1vv>
The Bitcoin Blockchain, Human/Civil Rights and Computer Crimes 7
<https://docs.google.com/document#heading=h.e9qgh4ilxr33>
Goldman Sachs’ Organization HR Management Analysis (MoneyGram and Ripple)
8 <https://docs.google.com/document#heading=h.6rxby3kdxyer>
www.JUMO.World and Banking Africa 9
<https://docs.google.com/document#heading=h.i05ave1q4rbi>
Earth_ID: Because Owning Your Identity is a Human Right 10
<https://docs.google.com/document#heading=h.fsblwc7lwh45>
CryptoBank Environmental Analysis 11
<https://docs.google.com/document#heading=h.hilka03j6nc>
The NEXO.io Conundrum 12
<https://docs.google.com/document#heading=h.q9hwlwczdyhq>
The Fireblocks Conundrum 13
<https://docs.google.com/document#heading=h.tkx9xi4801g>
Computer Software and the Blockchain Platform 14
<https://docs.google.com/document#heading=h.49okvir8vwmq>
Virtual Currency: Computer Software Protocols and Processes 15
<https://docs.google.com/document#heading=h.u1gw0w9y52p>
Bank.org: Revolutionary Approaches to Agile Innovation 16
<https://docs.google.com/document#heading=h.2aa81ldquwqy>
Conclusion 17 <https://docs.google.com/document#heading=h.wuzm4oh1p4gz>
Bibliography 19 <https://docs.google.com/document#heading=h.1qq38owyyhee>
Introduction
Crypto and Blockchain are each a Human Right.
For all, everywhere.
1.
How does New York based bank fraud happen from the inside? People who
commit crimes comprise departments and divisions of corporate
organizations, and some current Human Resources (HR) management cultures
lend well to the committing of crimes.
2.
What organizational HR management design structures are at play to
architectect such fraud for bespoke juristical instances?
3.
Is there a unique opportunity for a fresh and clean New York-based
international bank such as Bank.org?
xNY.io argues that modern and innovative Executive Suites pioneer
organizational HR management with the CEO and CFO leading the pack as the
most ethical example for members in their organization. This key
distinction calls for leaders to always adhere to a very strict, yet
progressive, standard of ethics, even when it’s inconvenient.
World renowned executive Jack McCullough suggests strict adherence is
necessary, especially when it’s inconvenient. McCullough says that if
you’re seen as a CEO and CFO “who will compromise when convenient, this
approach will cause colleagues to consider all the talk about ethics to be
lip service” (McCullough 2019)
<https://sciwheel.com/work/citation?ids=10934566&pre=&suf=&sa=0>.
The leadership at xNY.io is clear-eyed, recognizing the importance of an
extensive review program which seeks to explore all aspects of the
following criteria as part of Legal, Compliance, and Governance (Bloomberg
2021) <https://sciwheel.com/work/citation?ids=10935129&pre=&suf=&sa=0>,
which is our internal due diligence framework based on first class industry
standards and best practices (xNY.io | Bank.org n.d.)
<https://sciwheel.com/work/citation?ids=10934818&pre=&suf=&sa=0>.
In summary, this HR management innovation essay outlines and explores three
key concerns for modern Bank and CryptoBank organizations. These concerns
are signaled by our regulators who rightly suggest that it is critically
important that the organizers identify, at the beginning of the process, an
available management team and board of directors (NY-DFS 2008)
<https://sciwheel.com/work/citation?ids=10935584&pre=&suf=&sa=0>:
1.
The theory of modern virtual currency cross-border regulation logic (Larson
2020a) <https://sciwheel.com/work/citation?ids=10935777&pre=&suf=&sa=0>.
2.
How to protect xNY.io’s strategic partnership with Bank.org and its
mandate to pioneer innovation(s) and noble advancement of modern
international banking?
3.
Whereas, it is essential to safeguard virtual currency and its potential
to galvanize international, economic and social advancement of all
peoples (United
Nations 1948)
<https://sciwheel.com/work/citation?ids=10936242&pre=&suf=&sa=0>.
Most importantly, what organizational HR management structures are
necessary to execute the proposed xNY.io and hybrid model framework, while
engaging agile innovation to explore the potential of growing Bank.org into
the World’s Best Bank and headquartered in New York (NY-DFS 2019)
<https://sciwheel.com/work/citation?ids=10936021&pre=&suf=&sa=0>?
Focus, Goals and Objective(s)
Why would a New York bank build organizational HR strategies with the sole
purpose of taking advantage of the most vulnerable for exorbitant profit?
xNY.io’s focus is to fill a need in clarifying New York’s virtual currency
standards to achieve progressive innovation while constantly promoting
respect for human rights and personal freedoms by progressive measures,
national and international, to secure their universal and effective
recognition and observance across all global territories of business,
protecting all peoples and all nations (United Nations 1948)
<https://sciwheel.com/work/citation?ids=10936242&pre=&suf=&sa=0>.
Our simple strategy rests in the fact that virtual currency has
cross-border utilities (European Commission 2021)
<https://sciwheel.com/work/citation?ids=10951557&pre=&suf=&sa=0>. Our real
world experience has uncovered the strategy of a New York bank's
misemployed Manhattan Island as a walled garden for bad HR management camps
while wrongfully profiting off of the back of the most vulnerable across
global markets (Law 360 2021)
<https://sciwheel.com/work/citation?ids=10951562&pre=&suf=&sa=0>. Our goal
is to profit off the pivot from the textbook definition of marketplace
manipulation, discussed herein related to the feasibility of automating stock
market manipulation (Association for Computing Machinery 2020)
<https://sciwheel.com/work/citation?ids=10937107&pre=&suf=&sa=0>.
The Supreme Court placed emphasis on the central role of deception to the
concept of fraud.“ (T)he words ‘to defraud’ . . . primarily mean to cheat,
. . . usually signify the deprivation of something of value by trick,
deceit, chicane, or overreaching, and . . . do not extend to theft by
violence, or to robbery or burglary.” (Hammerschmidt v. United States 1924)
<https://sciwheel.com/work/citation?ids=10937278&pre=&suf=&sa=0>.
Bank.org feels confident in our knowledge and our direct dialogue with over
100 of the world’s leading scholars on the subject of international
law: (Morris
2008) <https://sciwheel.com/work/citation?ids=10942187&pre=&suf=&sa=0>
-
The International Criminal Court investigates and punishes people for
genocide, crimes against humanity, and war crimes (Wikipedia 2021a)
<https://sciwheel.com/work/citation?ids=10942253&pre=&suf=&sa=0>.
-
The International Court of Justice, sometimes referred to as the World
Court, has two major functions. Firstly, it settles disputes, which the
member countries may bring before it. Secondly, it may give its opinions on
legal matters (Wikipedia 2021b)
<https://sciwheel.com/work/citation?ids=10942250&pre=&suf=&sa=0>.
The objective of xNY.io’s research essay summarizes the discussion of New
York bank organizations and the corresponding HR management architectures
designed to target maximizing profits through conscious marketplace
manipulation structures. The best xNY.io CryptoBank must be concerned with
pioneering a business beyond leveraging computer crimes, a marketplace
manipulation matter associated with current New York BitLicense
architecture and subject to our attention related to
cross-border/international organized groups that are cyber-based in
New York (Federal
Deposit Insurance Corporation 1989)
<https://sciwheel.com/work/citation?ids=10942239&pre=&suf=&sa=0>.
Strategic Intent
Imagine trying to open the best bank in the world and running up against
BitLicense regulatory arbitrage (Poster 2019)
<https://sciwheel.com/work/citation?ids=10959604&pre=&suf=&sa=0> just a few
Manhattan blocks away.
Composing a richly robust innovation strategy calls for a clear and honest
appraisal of current marketplace conditions and identifying the firm’s
current status. This requires xNY.io to not only be ambitious but also
extremely articulate in outlining our strategic intent. We see our key
competitive advantage in cleverley leveraging our vision cohesively with
all available resources and modern ideals of Bank.org.
Bank.org is aware that our uniqueness is very difficult for competitors to
imitate. In her book Strategic Management for Technological Innovation,
Mellissa Schilling suggests that the New York banking sector may be
characterized as an oligopolistic industry in that there is a low degree of
rivalry. Schilling explains that sometimes competitors choose to avoid
head-to-head competition as a price collusion tactic (Schilling 2019)
<https://sciwheel.com/work/citation?ids=10951587&pre=&suf=&sa=0>.
Being extremely clear and transparent, xNY.io's business models emphasize
taking advantage of our competitors who have designed global regulatory
abtrigatre frameworks at the expense of our customers (Buchak et al. 2017)
<https://sciwheel.com/work/citation?ids=10956108&pre=&suf=&sa=0>.
Bank.org's stakeholder analysis highlights that many New York banks have
ignored the ethical and moral implications of designing HR management
structures with the sole purpose of training employees to act as
footmen/footwomen in defrauding a global customer base. Furthermore, these
bad actors revel in the naivety of potential rivals and government
regulators as an operative procedure of HR management.
Through an analysis of the best agile innovation strategy for execution,
xNY.io and Bank.org have partnered to engage both backward vertical
integration AND horizontal integration techniques (Tarver & James 2021)
<https://sciwheel.com/work/citation?ids=10951616&pre=&suf=&sa=0>:
-
xNY.io is vertically integrating backwards by producing our own advanced
blockchain technology for global payments.
-
Bank.org aims to actively engage leveraged buyouts of competitor banks,
a practice that is considered horizontal integration (Kenton & James
2021) <https://sciwheel.com/work/citation?ids=10951605&pre=&suf=&sa=0>.
>From the very beginning, xNY.io and Bank.org’s ethical and moral incentives
have been strategically integrated into a modern and innovative hybrid
infrastructure. Spanning key global functions including (but not limited to)
reserve management, international legal counsel, and public and government
affairs and relations, we consider ethics to be a quality management
concern. Honestly, the implications of our strategic intent are derived
from the morals of our founders who seek to efficiently secure the smooth
function of our cross-border operations.
Innovation Strategy
We recognize our competitors see modern innovation as merely improving
efficiency of obsolete legacy bank systems and processes to keep their
operations afloat. It is extremely troublesome that many New York bank HR
leaders’ modi operandi detail strategies of seeking new revenue channels
that target the most vulnerable across first to third world markets (Ripple
2013a) <https://sciwheel.com/work/citation?ids=10951672&pre=&suf=&sa=0>.
-
As part of our ethical leadership agenda, articulating xNY.io’s
strategic intent enables the firm to incorporate our innovation practice
into Bank.org’s cross-border development and rollout. Capital investments
are required as part of a multidimensional performance architecture, along
with real-time systems and computational analyses.
-
Our honest deliberation and critical assessment of xNY.io’s strategic
intent and development of new computational technologies brought to light
the concern of competitors' engagement in computer crimes discussed in
the following section.
We recognize that true innovation goes beyond juvenile process
efficiencies. Our innovation strategy constantly anticipates the future by
recognizing where industry peers are failing today. This allows us to
identify and execute products and services that are better - extremely
better - than what the industry offers today.
Schilling notes that successful and innovative firms question existing
price performance assumptions. They attract customers by developing and
introducing products that extend well beyond current market requirements
and help mold the market’s expectations for the future (Schilling 2019)
<https://sciwheel.com/work/citation?ids=10951587&pre=&suf=&sa=0>. This
separates us from our competitors' desperate attempts to cut costs rather
than ethically addressing and improving their HR operations with
corresponding moral incentives.
Pioneering Human Resources (HR) Management in Banking
As international scholars (Mills 2006)
<https://sciwheel.com/work/citation?ids=10951797&pre=&suf=&sa=0>, our
founders believe in the future of virtual currencies and blockchain
platform computer software. This belief has been cultivated and nurtured by
some of the most recognized pioneers of the global blockchain industry (Bourne
et al. 2018)
<https://sciwheel.com/work/citation?ids=10951810&pre=&suf=&sa=0>. We
consider virtual currency and blockchain technology to be precious,
appreciating assets with various growing benefits over the course of one’s
lifetime.
Rolling Stone profiles the New York bank JP Morgan Chase and the bank’s HR
management techniques, highlighting the conscious disregard of the ethical
and moral standards from Chase’s Executive Suite knowingly excited the
peddling of bad products stuffed with scratch-and-dent loans to investors
without disclosing the obvious defects of the underlying loans (Taibbi 2014)
<https://sciwheel.com/work/citation?ids=10961062&pre=&suf=&sa=0>.
Chase has repeated deal after deal with the same poor and fraudulent
organizational HR management methodology, as did many other banks. Rolling
Stone goes on to say, “It’s theft on a scale that blows the mind.”
New York banks and Silicon Valley technology firms have a long history of
not only challenging but actively attacking beliefs that virtual currency
and blockchain are innovative tools for means of payment and stores of
value, going so far as to launch an ever-popular campaign: “Bitcoin has no
value at all” (Torpey 2018)
<https://sciwheel.com/work/citation?ids=10951846&pre=&suf=&sa=0>.
It is safe to say that between New York and Silicon Valley, many
organizations, through their various HR management structures, have made
calculated efforts to kill the blockchain economy before it even got off
the ground (Al-Naji et al. 2018)
<https://sciwheel.com/work/citation?ids=10951869&pre=&suf=&sa=0>.
-
For example, New York, Europe and Africa are connected by a freeway of
cross-border arbitrage frameworks. Due to easily exploitable laws in
developing countries, some BitLicensees’ operations straddle New York,
Europe and Africa to evade detection and prosecution from law enforcement.
-
Through various HR management structures, New York banks have
consciously exacerbated regulatory loopholes resulting in virtual
currency market manipulation affecting international computer technology
systems and software such as the Bitcoin blockchain (Conway 2020)
<https://sciwheel.com/work/citation?ids=10951897&pre=&suf=&sa=0>.
-
Speaking generally, at least during the Bitlicense’s 2015-2020
implementation phase, New York banks likely leveraged the BitLicense
seeking to increase profits from cross-border virtual currency market
manipulation (Pettinger 2019)
<https://sciwheel.com/work/citation?ids=10960704&pre=&suf=&sa=0>.
-
The entire design for executing a loophole virtual currency standard
only comes into practice if a group of New York HR managers, at the
direction of the Executive Suite, puts together a scheme in secret to
manipulate a bunch of technical rules that laymen don’t understand
to deprive
people of their money (Bagchi 2020)
<https://sciwheel.com/work/citation?ids=10948490&pre=&suf=&sa=0>.
>From the position of absolute and essential need of becoming a leading
international bank, Bank.org has no other choice than to pioneer a
necessary HR culture that supports our primary activities of operation. It
is true that xNY.io came into existence as a tech-based response to the
stated problems that specifically addresses both the threats of future
damage and the current cross-border computer crime merry-go-round
responsible for extortionate damage already inflicted.
“We’ve got to change the cost-benefit calculus of criminals and
nation-states who believe they can compromise U.S. networks, steal U.S.
financial and intellectual property, and hold our critical infrastructure
at risk, all without incurring any risk themselves...” (Wray 2020)
<https://sciwheel.com/work/citation?ids=10936531&pre=&suf=&sa=0>.
The Bitcoin Blockchain, Human/Civil Rights and Computer Crimes
Bank.org is wise to objectively research and strategically organize its HR
leadership position as a pioneer, in comparison to current New York bank
management structures. Given that honest and fair dealing of virtual
currency is critical to blockchain technology, should admitted felons and
serial miscreants (Martens & Martens 2020)
<https://sciwheel.com/work/citation?ids=10948539&pre=&suf=&sa=0> be allowed
to further expand their racket via global regulatory arbitrage and/or
computer crimes?
1.
Satoshi Nakamoto’s Bitcoin whitepaper states, “What is needed is an
electronic payment system based on cryptographic proof instead of trust,
allowing any two willing parties to transact directly with each other
without the need for a trusted third party” (Nakamoto 2008)
<https://sciwheel.com/work/citation?ids=10951932&pre=&suf=&sa=0>.
2.
New York State Human/Civil rights laws are applicable internationally.
“If a resident person or domestic corporation violates any provision of
this article by virtue of the provisions of this section, this article
shall apply to such person or corporation in the same manner and to the
same extent as such provisions would have applied had such act been
committed within this state except that the penal provisions of such
article shall not be applicable” (N.Y. Executive Law 2019)
<https://sciwheel.com/work/citation?ids=10952341&pre=&suf=&sa=0>.
3.
Congress amended the definition of “protected computer” to make clear
that this term includes computers outside of the United States so long as
they affect interstate or foreign commerce or communication of the United
States. This change addresses situations where an attacker within the
United States attacks a computer system located abroad. This change also
addresses situations in which individuals in foreign countries route
communications through the United States with intent to extort from any
person any money or other item of value, transmitted via interstate or
foreign commerce (U.S. Congress 2002)
<https://sciwheel.com/work/citation?ids=10952375&pre=&suf=&sa=0>.
Courts have interpreted expansively to define not only schemes to defraud
individuals of money or property, but also schemes to defraud individuals
of intangible interests and rights. Additionally, both mail and wire fraud
statutes have been expanded to include schemes to deprive individuals
of “honest
services” (Eltringham 2015)
<https://sciwheel.com/work/citation?ids=10951979&pre=&suf=&sa=0>.
What organizational HR management techniques are required for an enterprise
to actively convince hundreds, if not thousands, of employees, clients and
customers to pursue their strategy while knowing it was fatally flawed?
Goldman Sachs’ Organization HR Management Analysis (MoneyGram and Ripple)
MoneyGram, which has about 227,000 global money transfer agent locations in
191 countries and territories, was recapitalized in 2008 (same year of
Bitcoin's whitepaper). Goldman Sachs acquired an equity interest of 63
percent in MoneyGram for about $710 million. Per the 2008 agreement,
MoneyGram also received $500 million in debt financing from Goldman
Sachs (Cordeiro
2011) <https://sciwheel.com/work/citation?ids=10952410&pre=&suf=&sa=0>.
Walmart is the only MoneyGram agent, for both the Global Funds Transfer and
Financial Paper Products segments, that accounts for more than 10% of
revenue. In 2020, Walmart accounted for 13% of total MoneyGram’s revenue
and 16% in 2019 and 2018. Goldman Sachs (Investor) has a Participation
Agreement with Walmart Inc. (Walmart) under which the Investor is obligated
to pay Walmart certain percentages of any accumulated cash payments
received by the Investor in excess of the Investor's original investment in
the Company (MONEYGRAM INTERNATIONAL INC 2021)
<https://sciwheel.com/work/citation?ids=10952491&pre=&suf=&sa=0>.
In 2016, Ripple received New York’s First NY-DFS BitLicense for an
Institutional Use Case of Digital Assets (Larsen 2016)
<https://sciwheel.com/work/citation?ids=10953308&pre=&suf=&sa=0>. Shortly
after being NY-DFS accredited, Ripple announced it was teaming up with
MoneyGram to test payments using Ripple’s xRP virtual currency. During this
time, Ripple was making headlines as the xRP digital currency had surged —
and fallen — dramatically (Browne 2018)
<https://sciwheel.com/work/citation?ids=10953324&pre=&suf=&sa=0>. Soon
after, Ripple announced a $50 million investment in MoneyGram snagging a
10% equity stake in the firm. Brad Garlinghouse, Ripple’s CEO, added that
his firm would support MoneyGram’s “further expansion” into the European
and Australian payment corridors (De 2019)
<https://sciwheel.com/work/citation?ids=10953333&pre=&suf=&sa=0>.
-
Connecting the dots, MoneyGram is now one of the most expensive transfer
providers (Tierney 2019)
<https://sciwheel.com/work/citation?ids=10953437&pre=&suf=&sa=0> on planet
Earth. Customers incur fees for postal mail, telephone calls, electronic
mail, and other computerized messaging services.
-
Computer crimes as a threat are no less of a threat because it is
contingent, because the speaker does not intend or is unable to carry it
out when the threat was not directly communicated to the MoneyGram customer
as a target, or because the language used might be considered cryptic or
ambiguously not part of the current New York BitLicense mandate.
-
Ripple simply made MoneyGram’s business more efficient, thus accruing
more profits for Goldman Sachs directed out of Manhattan. From 2019 -
2020, MoneyGram received more than $40 million in market development fees
from Ripple Labs in return for providing liquidity to its On-Demand
Liquidity (ODL) network. It can be calculated that 10%-15% of the proceeds
came from Walmart customers, who are some of the most disenfranchised
Americans financially.
Over the last five years, through conscious organizational HR
management, Goldman
Sachs created layer upon layer of New York BitLicense-related disguises and
cross-border systems under potential conspiracy and plausible deniability
to computer crimes and marketplace manipulation. Goldman Sachs' various
direct and/or indirect BitLicensee connections profit daily from virtual
currency market manipulation computer crimes with cross-border reach,
operating as a large syndicate group from lower Manhattan.
www.JUMO.World and Banking Africa
What is astonishing is that Ripple is powering some of JUMO’s bank
customers (Ripple 2020)
<https://sciwheel.com/work/citation?ids=10959408&pre=&suf=&sa=0>, in a
troublesome manner similar to MoneyGram.
New York banks have a long and profitable history of exploiting regulatory
arbitrage. Similar to the MoneyGram instance, some evidence shows that
Goldman Sachs also seems to have entered Africa. Given that several
enforcement actions and lawsuits in the United States specifically targeted
banks’ treatment of minority borrowers (Taibbi 2014)
<https://sciwheel.com/work/citation?ids=10961062&pre=&suf=&sa=0>, it may
not be surprising to learn of www.Jumo.World or “JUMO” (Buchak et al. 2017)
<https://sciwheel.com/work/citation?ids=10956108&pre=&suf=&sa=0>.
A domain extension, in this case “.World” domain, is the targeted subject
area of a computer program. It is a term used in software engineering
(Wikipedia
2021) <https://sciwheel.com/work/citation?ids=10968017&pre=&suf=&sa=0>:
-
During the fourth quarter of 2018, JUMO successfully finalized a $65
million capital raise that was led by Goldman Sachs in New York. JUMO is a
full technology software stack for building and running financial
services, targeted at the world’s most disadvantaged populations.
-
Today, JUMO operates across numerous African markets including Tanzania,
Ghana, Zambia, Kenya, Uganda, and most recently in Pakistan, with plans to
expand further across the sub-continent.
-
Since its launch in 2014, more than 15 million people have saved or
borrowed on the JUMO platform, with over $1.6 billion in funds disbursed to
customers. Nearly 70% of JUMO’s customers are micro and small business
owners.
JUMO targets the unbanked population across several emerging and developing
markets. A variety of JUMO’s partnerships with leading banks and mobile
network operators creates a marketplace where consumers can access
financial services and banks can access a new pool of mobile money
customers (Vostok Emerging Finance Ltd 2020)
<https://sciwheel.com/work/citation?ids=10955874&pre=&suf=&sa=0>.
Given the regulatory environment in Africa, it could be suggested that from
New York, Goldman Sachs and Ripple’s organizational HR management
structures once again aim to profit from some of the most vulnerable of the
human population.
Earth_ID: Because Owning Your Identity is a Human Right
The modus operandi of JUMO’s business is a type of malicious bank software
designed to encrypt or otherwise block access to valuable data (e.g. Digital
Identity) until the victim agrees to provide a specified payment.
The population of the African continent is approximately 1.2 billion
people. Imagine a whole continent of people with no proof of identity and
therefore no chance of having access to financial services, economic
opportunities, or formal employment. These are basic services that are
taken for granted and sadly are all too often denied to so many in our
world today. Many countries in Africa lack the necessary means to establish
and maintain basic systems of identity management, such as the registration
of births, especially for the rural poor and underprivileged (Plumer et al.
2020) <https://sciwheel.com/work/citation?ids=10956171&pre=&suf=&sa=0>.
Earth_ID has plans to pilot the launch of it’s decentralized digital
identity platform in collaboration with University of Nicosia’s (UNIC) very
own African Partner, UNICAF. UNICAF has a physical presence on eleven
campuses throughout Sub-Saharan Africa. We welcome the students and staff
of UNICAF to be Earth_ID’s very first adopters, community leaders and
validators in trust to our decentralized identity solution. Goldman Sachs
from New York is a lead investor in UNICAF (Chege 2018)
<https://sciwheel.com/work/citation?ids=10958197&pre=&suf=&sa=0>.
According to the United Nations Digital Solutions Centre, the creation of a
unique personal United Nations ID (Earth_ID) using blockchain technology,
which is portable across organizations (Dumitriu 2020)
<https://sciwheel.com/work/citation?ids=10956154&pre=&suf=&sa=0>.
-
The proposal foresees that every United Nations organization could
become a trusted authority writing information onto the blockchain. The
organizations could run their own nodes separately, while the system will
ensure scalability and interoperability.
-
The Inspector recommends that the executive heads of the United Nations
organizations support the creation of a United Nations digital ID. This
will have multiple long term positive consequences in terms of saving time
and resources, facilitating staff mobility in allowing certification and
recognition of their knowledge and skills, reducing bureaucracy, and
enhancing system-wide coherence.
The descriptive definition of regulatory arbitrage suggests that New York
banks’ organizational HR management, with direction from the Executive Suite,
seeks to saturate lending to markets with more minorities and worse
socioeconomic conditions (Buchak et al. 2017)
<https://sciwheel.com/work/citation?ids=10956108&pre=&suf=&sa=0>.
CryptoBank Environmental Analysis
How can xNY.io innovate from underdogs to elite high performers, becoming
the best in the world?
xNY.io - CryptoBank wants to create the best World Crypto Bank known to
humanity, and we plan to do that expeditiously in 40+ countries and fiat
currencies. xNY.io has a problem: We are displeased with Ripple powering
customers like MoneyGram, Santander Bank and the other 300+ banking
customers. Our frustrations hinge on Ripple seeming to be propping up the same
bad banks that more or less rival Bitcoin's entire mission (Larson 2020b)
<https://sciwheel.com/work/citation?ids=10959063&pre=&suf=&sa=0>.
Furthermore, instead of putting the MoneyGram and other bad traditional
banks out of business, Ripple is looking to profit off of cross-border
payment startups similar to our best World Crypto Bank (Ripple 2013b)
<https://sciwheel.com/work/citation?ids=10959314&pre=&suf=&sa=0>.
Market segmentation determines groups of customers with common needs and
wants. All over the world, young people strive to make money. Those who are
at the beginning of the life road plan to grow financially. The
high-interest rate of xNY.io deposit accounts will help customers make
desirable choices for healthy and prosperous financial futures. Moreover,
geographically, xNY.io has a keen focus to improve banking in developing
countries on the African continent to help deprived people obtain the
rights of digital identity and interdependent modern bank accounts with
innovative products and services.
-
Digital asset trading platforms like NEXO.io in Europe powered by
Fireblocks in New York hop from more regulated jurisdictions to less
regulated or unregulated countries, leading to so-called regulatory
arbitrage or currency speculation (Pettinger 2019)
<https://sciwheel.com/work/citation?ids=10960704&pre=&suf=&sa=0>.
-
NY-DFS and FDIC regulators have more trouble detecting and blocking
illicit digital asset flows as virtual currency transactions are diverted
away from compliant regulated Fireblocks in New York to unregulated trading
gateway venues and peer-to-peer protocols that are directly against NY-DFS’
BitLicense mandate (FTI Consulting 2021)
<https://sciwheel.com/work/citation?ids=10960677&pre=&suf=&sa=0>.
The chain of financial service providers includes several intermediaries,
each drawing their own commission against the services provided. These
operating principles date several years back, and it is difficult to
make a paradigm
shift from this existing operational hierarchy. This constraint is being
utilized by middlemen and the established market players. Financial
conglomerates use their supremacy, as well, to make sure their operations
continue unchallenged. The industry generally fails to serve a sizable part
of the community and this gap can only be bridged by new players. However,
the strong market hold of the established players makes it seemingly
difficult for innovators to contribute.
The NEXO.io Conundrum
Our role model for creating the best World Crypto Bank is NEXO.io. While
Ripple's business of leveraging digital currency and blockchain technology
is disheartening, the great success of NEXO's crypto bank and card is
impressive. Case in point, NEXO's token and overall business solution is a
better example (Trenchev 2018)
<https://sciwheel.com/work/citation?ids=10959329&pre=&suf=&sa=0>.
NEXO is a great example for our best World Crypto Bank' but is funded by
Goldman Sachs (Roony 2018)
<https://sciwheel.com/work/citation?ids=10959512&pre=&suf=&sa=0>, Which
could be argued to be worse than Ripple. Goldman's blockage of
crypto/blockchain development in the United States (U.S. Congress 2002)
<https://sciwheel.com/work/citation?ids=10952375&pre=&suf=&sa=0> and
Digital Identity in Africa (Plumer et al. 2020)
<https://sciwheel.com/work/citation?ids=10956171&pre=&suf=&sa=0> cannot be
overlooked.
While Ripple is supporting the bad behavior of MoneyGram and other
traditional banks with cards, NEXO is just the best bad version of Ripple
funded by Sachs. Both are probably gaming the digital currency market and
global blockchain innovation, and possibly humanity as a whole.
Obviously, NEXO could get into trouble for operating an unregulated bank
fast (Jennings 2018)
<https://sciwheel.com/work/citation?ids=10959529&pre=&suf=&sa=0>:
1.
Moreover, NEXO is, at various levels, illegal in the United States where
the federal government regulates most banks (NEXO 2019
<https://sciwheel.com/work/citation?ids=10959498&pre=&suf=&sa=0>). For
example, in New York, some of the NEXO token benefits are forbidden by
NY-DFS (Sokolowski 2021)
<https://sciwheel.com/work/citation?ids=10959577&pre=&suf=&sa=0> .
2.
Nexo doesn't have a Bitlicense, but they still operate in New York
(u/zylstrar
2019) <https://sciwheel.com/work/citation?ids=10959567&pre=&suf=&sa=0>.
New York State Attorney General Letitia James has made it clear that
virtual currency firms must abide by the BItLicense or risk being
shut down (Sharma
2021) <https://sciwheel.com/work/citation?ids=10959571&pre=&suf=&sa=0>.
3.
Additionally, United States authorities could force NEXO to offer
Federal Deposit Insurance Corporation (FDIC) insurance on its
accounts (Buchak
et al. 2017)
<https://sciwheel.com/work/citation?ids=10956108&pre=&suf=&sa=0> .
It could be argued that Ripple (xRP) and NEXO.io (NEXO) built entire global
operations as direct/indirect BitLicensees with intent to profit from
various cross-border computer crimes such as market manipulation while
being partially funded and/or directed out of New York (U.S. Congress 2002)
<https://sciwheel.com/work/citation?ids=10952375&pre=&suf=&sa=0>.
However, NEXO operates like a bank. To explain, clients put cryptocurrency
in a wallet, borrow against it and receive funds through the NEXO wallet.
NEXO claims it can tap some huge markets that include crypto investors,
crypto miners, and hedge funds. Hence, NEXO looks like an investment bank.
Tellingly, NEXO looks a great deal like Goldman Sachs’ Marcus platform. For
example, both NEXO and Marcus offer loans and savings accounts.
The Fireblocks Conundrum
A few blocks south of Times Square in New York City, Fireblocks (Google
Maps 2021) <https://sciwheel.com/work/citation?ids=10959908&pre=&suf=&sa=0>
powers the global operations of NEXO.io headquartered in Europe. The CEO of
Fireblocks has discussed his firm's $135 million investment led by BNY
Mellon and others: “‘While we have no plans to become a bank, we believe
our infrastructure will lend itself perfectly to power an entirely new era
of financial services,’ Shaulov added. ‘Developing products to bridge
digital and traditional assets is foundational to the future of custody.’
Roman Regelman, BNY Mellon’s asset servicing CEO and digital head said,
‘Following significant due diligence and market research, we recognize
Fireblocks as a market leader in providing secure technology to support
digital asset services’” (Shome 2021)
<https://sciwheel.com/work/citation?ids=10959918&pre=&suf=&sa=0>.
-
As previously noted, New York, Europe and Africa are connected by a
freeway of cross-border arbitrage frameworks. Due to easily exploitable
laws in developing countries, some BitLicensees’ daily operations straddle
New York, Europe and Africa to evade detection and prosecution from law
enforcement (Larsen 2016)
<https://sciwheel.com/work/citation?ids=10953308&pre=&suf=&sa=0>.
-
The Financial Action Task Force (FATF) identifies the “Travel Rule,”
also known as “Regulatory Arbitrage,” as a stand-out concern that is
perhaps the most glaring example of the lack of global harmonization of
policies designed to combat illicit financial flows in the crypto markets.
Fireblocks in New York powering the European based NEXO.io’s Global
CryptoBank (Metodiev 2020)
<https://sciwheel.com/work/citation?ids=10961027&pre=&suf=&sa=0> operations
at worst fueled a black-market financial system and at best purposely and
deliberately existed outside of the NY-DFS BitLicense and bank industry
regulations (Cyber Digital Task Force 2020)
<https://sciwheel.com/work/citation?ids=10960464&pre=&suf=&sa=0>.
Fred Ehrsam, co-founder and managing partner at Paradigm (Ehrsam 2021)
<https://sciwheel.com/work/citation?ids=10959925&pre=&suf=&sa=0>, is a lead
investor in Fireblocks where he also serves as a board member. Previously,
Ehrsam co-founded Coinbase, the largest cryptocurrency company in the US,
and held the role of president from 2012 to 2017. Ehrsam purchased his
first Bitcoin in 2011 and has been an angel investor in some of the space’s
most formative companies. Prior to Coinbase, Ehrsam was a foreign exchange
trader at Goldman Sachs in New York. Ehrsam holds a B.S. in Computer
Science and Economics with honors and departmental distinction from Duke
University (Fireblocks 2020)
<https://sciwheel.com/work/citation?ids=10959593&pre=&suf=&sa=0>.
Computer Software and the Blockchain Platform
International Business Machines Corporation (IBM) is one of the world’s
largest computer firms and is headquartered in New York (Wikipedia. 2021)
<https://sciwheel.com/work/citation?ids=10959864&pre=&suf=&sa=0>. IBM
distinguishes the blockchain platform technology as computer software
(International
Business Machines Corporation (IBM) 2021)
<https://sciwheel.com/work/citation?ids=10959869&pre=&suf=&sa=0>. Given
IBM’s modus operandi, it could be concluded that the Bitcoin blockchain is
also computer software.
Yet, New York banks can use those same innovations for their own illegitimate
ends, imposing great costs on the public. Today, few technologies are more
potentially transformative and disruptive—and more potentially susceptible
to abuse—than virtual currency (Cyber Digital Task Force 2020)
<https://sciwheel.com/work/citation?ids=10960464&pre=&suf=&sa=0>.
Virtual currency fraud is a serious problem for such a developed country as
the United States, whose bank regulators have drawn attention to the
increase of these crimes. Having discovered that an unregulated virtual
currency sphere (such as in Africa, or other developing markets) is very
popular among virtual currency fraudsters (Prior 2020)
<https://sciwheel.com/work/citation?ids=10959948&pre=&suf=&sa=0>, the SEC
has alluded that this kind of regulatory arbitrage fraud was concerning (U.S.
Securities and Exchange Commission (SEC) n.d.)
<https://sciwheel.com/work/citation?ids=10959942&pre=&suf=&sa=0>.
-
An uncoordinated regulation can potentially have a stifling effect by
way of creating inconsistent regulatory requirements on top of increased
compliance costs to the industry.
Virtual Currency: Computer Software Protocols and Processes
The Internal Revenue Service (IRS) classifies virtual currency such as
Bitcoin as a computer software code. For example, Bitcoins counted at 21
million corresponds to a specific number of mining rewards that can be
given, and this is all written into a code (Yamalis 2018)
<https://sciwheel.com/work/citation?ids=10960440&pre=&suf=&sa=0>.
1.
xNY.io’s key definition of virtual currency computer crimes is a
consistent message across markets. These crimes are relatively new, having
been in existence for only as long as Bitcoin has, which explains how
unprepared society, and the world in general, is towards combating these
crimes (Larson 2021a)
<https://sciwheel.com/work/citation?ids=10948534&pre=&suf=&sa=0> .
2.
Technological innovation and human flourishing are complementary
concepts, but the former does not guarantee the latter. Good public policy
along with ethical CEOs and CFOs at New York banks operating international
HR management organizations pioneer innovation of such policy (Eltringham
2015) <https://sciwheel.com/work/citation?ids=10951979&pre=&suf=&sa=0>.
3.
Marketplace manipulation and virtual currency regulatory arbitrage
undoubtedly stifles innovation and human flourishing. The absence of
protection under the law can endanger progress across both dimensions. It
takes careful consideration, and a deep and ongoing immersion in the facts,
to understand when and how law should intervene (FTI Consulting 2021)
<https://sciwheel.com/work/citation?ids=10960677&pre=&suf=&sa=0>.
Even in societies where transformative scientific and technological
advancements are achievable, ethical and moral CEOs and CFOs play a
critical mediating role. In the wrong hands, or without appropriate
safeguards and oversight, these advancements can facilitate great human
suffering.
Keeping all this in mind with a positive/optimistic attitude, a series of
smart and calculated leveraged buyouts can innovate beyond New York banks’
cross-border computer crime(s) such as (Prior 2020)
<https://sciwheel.com/work/citation?ids=10959948&pre=&suf=&sa=0>:
1.
Conspiracy to Commit Fraud and Related Activity in Connection with
Computers
2.
Conspiracy to Commit Wire Fraud
3.
Intentional Damage to a Protected Computer
4.
Transmitting a Demand in Relation to Damaging a Protected Computer
The U.S. government could appropriately assert jurisdiction over such
offenses anywhere in the world, consistent with due process, under the
principle of protective jurisdiction. That principle holds that, “[F]or
non-citizens acting entirely abroad, a jurisdictional nexus exists when the
aim of that activity is to cause harm inside the United States or to U.S.
citizens or interests” (Cyber Digital Task Force 2020)
<https://sciwheel.com/work/citation?ids=10960464&pre=&suf=&sa=0>.
Bank.org: Revolutionary Approaches to Agile Innovation
A prerequisite to protecting our future customers' lifelong returns and
Bank.org’s profits calls for Bank.org’s engagement of agile innovation in
manufacturing new and revolutionary approaches to international banking
from our New York headquarters.
The key aim of the Bank.org endeavor, and our primary goal, is to attain
the legitimate financial inclusion and economic prosperity of all people,
including the excluded, under-privileged and under-served. Bank.org is
taking advantage of the New York banking industry at a crossroads. On the
one hand, digital banking services are rising to the forefront and drawing
increasing interest from customers. On the other, brick-and-mortar banking
remains an important way to connect with customers on a local and personal
level.
Bank.org intends to be a true borderless enterprise serving customers in
over 200 jurisdictions and 40+ fiat and virtual currencies.
1.
Bank.org has the luxury of an opportunity to be fresh, clean and pure in
comparison to many of our legacy “multiple felon” bank peers directing
global operations out of New York.
2.
Citibank has become the latest bank to be sued by a British currency
investment firm over allegations that its traders manipulated foreign
exchange markets for profit. Furthermore, expanding litigation accuses the
company of trade front-running.
3.
Bank.org’s scope as an international bank engages xNY.io to lead our
virtual currency innovation practice. xNY.io is a pioneering instrument to
elegantly complement Bank.org’s international bank operations.
The best bank in the world has energy to pioneer relentless HR innovation
with passion to create those means, build those processes and those systems
that will facilitate inclusive solutions to those problems which rob so
many of a chance to realize their goals and achieve their full potential.
Bank.org’s barriers to global market penetration include government(s) that
sponsor our peers who historically do not factor in the social benefits of
bank competition or of effective natural monopoly regulation of global New
York firms like Goldman Sachs. That is, regulators may grant licenses to
firms that are operating at a high level as state firms and so appear
valuable to private markets. This experience is supported by Bank.org’s
analysis and vision of the best performing global online institutions
(versus money center banks), which shows the principle in practice.
Conclusion
2021 in New York now brings us to cooperation versus competition and
rationality versus altruism. As with many situations in real-life, the
games are often not zero-sum, but by cooperative efforts all players can be
better off (Larson 2021b)
<https://sciwheel.com/work/citation?ids=10959166&pre=&suf=&sa=0>.
In 1973, John Maynard Smith presented an idea explaining game theory and
how alpha culture exists in societies. Maynard’s hypothesis asked you to
imagine a world with doves and hawks. If there would be only hawks, their
fights would be devastating to their population. If there would be only
doves, they would be susceptible to any intruders, therefore such a
population would also not be stable. But the right combination of hawks and
doves would be evolutionarily stable (Smith & Corbin 1973)
<https://sciwheel.com/work/citation?ids=10959298&pre=&suf=&sa=0>.
-
We witness again and again that US American enterprises (aka New York
Banks), in particular, are being built by one or two supposedly shiny
figures (CEO or CFO) who have questable ethics and morals.
-
The qualitative effect on organizational HR Management is an Executive
Suite that assembles subpar teammates around him or her.
-
The firms focus on the growing experience and network of that single
person and are closely associated with the individual’s character. Business
relationships are being entered and trust being built with that individual
rather than the firm as an institution.
Startup companies like xNY.io and Bank.org that dare to explore more novel
approaches and non-hierarchical structures, though, show successes, as do
larger organizations formalizing and adopting respective strategies.
However, within the New York banking community with its various regulators,
there appears to be a window of opportunity for smart innovation.
Anecdotal observations yet again identify the root cause in the vast
multidisciplinary nature of the domain, and in the all-so-technical
backgrounds of its protagonists where Executive Suites and organizational
HR managers cling to their old habits while placing less importance on
innovation and executing modern organizational insights bank wide.
Behavioral and organizational research impressively underline a very simple
“game,” in which the conditions for survival (be nice, be provocable,
promote mutual interest) seem to be the essence of ethics and morality.
While this does not yet amount to a science of ethics or morality, the game
theory approach has clarified the conditions required for the evolution and
persistence of cooperation, and shows how Darwinian natural selection can
lead to complex behavior, including notions of morality, fairness, and
justice, beyond alpha culture.
In the 1980s, Professor of Political Science Robert Axelrod ran a
tournament inviting strategies from collaborators all over the world.
Axelrod found that the winning strategy that performed the best overall
(not in every game, but on average), was “Tit-for-Tat,” also called
look-back strategy or reciprocal altruism. It worked simply by starting the
first iteration with cooperation, then looking back at the opponent’s last
move and copying it in the next iteration (Axelrod 1980)
<https://sciwheel.com/work/citation?ids=10959358&pre=&suf=&sa=0>.
In summary, the best strategies were found to have these surprising
properties:
1.
Be nice – don‘t be the first to defect.
2.
Be provocable – return actions, both in retaliation and forgiveness.
3.
Don‘t envy – don‘t focus on beating the opponent, but on maximizing
your own score.
4.
Don‘t be tricky – anytime you try to exploit the opponent, you will
provoke revenge.
Bank.org is happy to make ethically sound risks to aggressively protect our
future customers' returns and our firm’s bottom line. The assumption our
competitors have is that historically New York banks’ CEOs and CFOs do not
engage the strategic roadmaps offered by a new aggressive market entrant
such as the xNY.io and Bank.org.
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