March 2024 - cypherpunks - lists.cpunks.org

NerdWallet, Syracuse Hit With 'Fraudulent' Bankruptcy Cases
by Gunnar Larson 05 Mar '24

05 Mar '24

NerdWallet, Syracuse Hit With 'Fraudulent' Bankruptcy Cases <https://www.law360.com/newyork/articles/1809531?nl_pk=ac5a3855-e47c-4403-be…> By Clara Geoghegan Personal finance platform NerdWallet, the city of Syracuse, New York, a Taco Bell franchisee and a financial tech company were targets of apparently phony bankruptcy cases opened in Delaware over the weekend by a frequent pro se litigant. 5 documents attached | Read full article » <https://www.law360.com/newyork/articles/1809531?nl_pk=ac5a3855-e47c-4403-be…> | Save to favorites » <https://www.law360.com/newyork/articles/1809531?nl_pk=ac5a3855-e47c-4403-be…>

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OpenAI Judge Denies Writers' Calif. IP Case 'First-To-File' Bid
by Gunnar Larson 05 Mar '24

05 Mar '24

OpenAI Judge Denies Writers' Calif. IP Case 'First-To-File' Bid <https://www.law360.com/newyork/articles/1809463?nl_pk=ac5a3855-e47c-4403-be…> By Bonnie Eslinger A California federal judge ruled Friday that a group of authors suing OpenAI for alleged copyright infringement cannot bar the Microsoft-backed company from defending itself against a similar suit in New York federal court, saying the plaintiffs' argument that the artificial intelligence startup engaged in forum shopping "holds no sway." Order attached | Read full article » <https://www.law360.com/newyork/articles/1809463?nl_pk=ac5a3855-e47c-4403-be…> | Save to favorites » <https://www.law360.com/newyork/articles/1809463?nl_pk=ac5a3855-e47c-4403-be…>

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Pearson Can't Escape Facebook Data-Sharing Privacy Suit
by Gunnar Larson 05 Mar '24

05 Mar '24

Pearson Can't Escape Facebook Data-Sharing Privacy Suit <https://www.law360.com/newyork/articles/1809864?nl_pk=ac5a3855-e47c-4403-be…> By Henrik Nilsson A New York federal judge on Friday refused to toss a proposed class action against online education company Pearson Education Inc. alleging it illegally shared subscribers' personal information with Meta Platforms Inc., saying the plaintiff sufficiently alleges Pearson disclosed his video viewing history to Facebook. Opinion attached | Read full article » <https://www.law360.com/newyork/articles/1809864?nl_pk=ac5a3855-e47c-4403-be…> | Save to favorites » <https://www.law360.com/newyork/articles/1809864?nl_pk=ac5a3855-e47c-4403-be…>

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Trump Blasts DA's Gag Order Motion In NY Hush Money Case
by Gunnar Larson 05 Mar '24

05 Mar '24

Trump Blasts DA's Gag Order Motion In NY Hush Money Case <https://www.law360.com/newyork/articles/1809857?nl_pk=ac5a3855-e47c-4403-be…> By Frank G. Runyeon Donald Trump's attorneys on Monday slammed the Manhattan district attorney's request for a gag order in the hush money case against the former president, arguing it would be unconstitutional to silence the "leading candidate in the 2024 election" in the midst of the primary season. 1 document attached | Read full article » <https://www.law360.com/newyork/articles/1809857?nl_pk=ac5a3855-e47c-4403-be…> | Save to favorites » <https://www.law360.com/newyork/articles/1809857?nl_pk=ac5a3855-e47c-4403-be…>

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Laptop Dustup Pits Steptoe & Johnson Against Bookkeepers
by Gunnar Larson 05 Mar '24

05 Mar '24

Laptop Dustup Pits Steptoe & Johnson Against Bookkeepers <https://www.law360.com/newyork/articles/1809575?nl_pk=ac5a3855-e47c-4403-be…> By Pete Brush A Manhattan federal judge on Monday prodded Steptoe & Johnson PLLC to try to settle claims that it unlawfully exploited the contents of a Pennsylvania accounting and tax concern's laptop, but the law firm's counsel denied it had any such device. Read full article » <https://www.law360.com/newyork/articles/1809575?nl_pk=ac5a3855-e47c-4403-be…> | Save to favorites » <https://www.law360.com/newyork/articles/1809575?nl_pk=ac5a3855-e47c-4403-be…>

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Gov't To Require Pensions To Disclose UK Investments
by Gunnar Larson 05 Mar '24

05 Mar '24

Gov't To Require Pensions To Disclose UK Investments <https://www.law360.co.uk/financial-services-uk/articles/1809117?nl_pk=a94fc…> By Martin Croucher The U.K. government said it will require pension schemes to disclose how much they invest in U.K. businesses, as part of a wider effort to tap into the sector for economic growth. Read full article » <https://www.law360.co.uk/financial-services-uk/articles/1809117?nl_pk=a94fc…> | Save to favorites » <https://www.law360.co.uk/financial-services-uk/articles/1809117?nl_pk=a94fc…>

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United Nations (UNFICYP) 60 Year Medal Ceremony
by Gunnar Larson 05 Mar '24

05 Mar '24

United Nations (UNFICYP) 60 Year Medal Ceremony: https://www.instagram.com/p/C4GxPRgNZtJ/?igsh=MWoyc2N1bm5iajJjMw==

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Re: Recipe for a CISO
by Karl Semich 04 Mar '24

04 Mar '24

yeah, and i’m crazy now of course whether that reverse engineering is done by hand by individuals, or entirely automated, or done by huge groups of people, has a big impact on what kinds of threats are encountered, and how to effectively handle them i think our current situations are hopefully temporary, where there is at least for me a lot of obscurity around specifics of information power layout. when conflicts find winners maybe that can change. if instead the role of the vulnerability researcher goes away (i don’t know, i’m not involved), this would of course also be a temporary situation as things become more and more open to problems arising something i didn’t mention in my email is the interception and mutation of communications, intertwines the digital and the human. hope you find good work if you are needing it i guess what i’m saying is there was big potential building around automation of analysis. On Mon, Mar 4, 2024 at 08:08 J.M. Porup <jm(a)porup.com> wrote: > If you will permit me to zoom out, the overall trend you have identified > is that security has moved up the stack to higher and higher layers of > abstraction. Since it is impossible to know all the systems, security > has specialized. And since security issues lurk at greater quantities > at higher layers of abstraction, it makes sense for someone in a CISO > role to focus on higher layers of abstraction (as opposed to, say, > focusing on reverse engineering a small cross-section of binaries > of interest.) > > jmp > > * Karl Semich <0xloem(a)gmail.com> [2024-03-04 13:52:04 +0000]: > > > it used to be knowing systems meant learning to look inside obscure > > binaries and figuring out how to turn them to your ends like an > > anthropologist decoding ancient tablets (breaking into systems by hand), > > and doing this so well that you could defend against others doing it > > effectively. basically, nobody else had any idea how anything worked, it > > seemed they were all living in fantasy worlds based on marketing > materials. > > > > it’s been a decade or two now for me, and i don’t know how it is in the > > present day. since the era of the dedicated hacker there are public tools > > maybe starting with metasploit that magnify power immensely. various > actors > > have stimulated serious reduction in the quality of new code while other > > groups have secured some systems very strongly, such as blockchains. > > > > phones and routers still languish without updates while vulnerabilities > sit > > in public databases to be used. things like this likely shift the power > > away from the researcher. > > > > i took one brief intro in cybersecurity and it was all AI, training > models > > to detect and respond to anomalies. > > > > and those same powerful entities put backdoors straight in the hardware, > > contributing to frustration of complete review. > > > > my personal experiences lend me to think that AI has been used on the > > offensive for quite some time now. it seems things may have also shifted > a > > ton toward social influence, which may even simply be more familiar to > most > > people. > > > > On Mon, Mar 4, 2024 at 06:24 Cyber Cyber Cyber Cyber < > > cybercybercybercyber(a)substack.com> wrote: > > > > > eye of newt and toe of frog > > > ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ > ͏ > > > ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ > ͏ ‌ > > > ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ > > > ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ > ͏ > > > ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ > ͏ ‌ > > > ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ > > > ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ > ͏ > > > ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ > ͏ ‌ > > > ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ > > > ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ > ͏ > > > ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ > ͏ ‌ > > > ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ > > > ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ > ͏ > > > ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ > ͏ ‌ > > > ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ > > > ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ > ͏ > > > ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ > ͏ ‌ > > > ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ > > > ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ > ͏ > > > ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ > ͏ ‌ > > > ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ > > > ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ > ͏ > > > ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ > ͏ ‌ > > > ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ ͏ ‌ > > > > Forwarded this email? Subscribe here > > > < > https://email.mg-d1.substack.com/c/eJxckr1yqzoUhZ8Gunj0A7YpKGJsEmkAX-cS89Oc… > > > > > for more > > > Recipe for a CISO > > > < > https://email.mg-d1.substack.com/c/eJxcksuSojwYQJ8m7LByA5sFC2ikfvof8TK2PfbG… > >eye > > > of newt and toe of frog > > > > > > J.M. Porup > > > < > https://email.mg-d1.substack.com/c/eJxckL3O0zAYRq_G3hzZr53YGTwAbUSDQAgGJBbk… > > > > > Mar 4 > > > > > > < > https://email.mg-d1.substack.com/c/eJxckL3O0zAYRq_G3hzZr53YGTwAbUSDQAgGJBbk… > > > > > > > > > > > < > https://email.mg-d1.substack.com/c/eJxcksFuozAQhp_G3BLZY6DhwCFbkpY2EKVKs8le… > > > > > > > > < > https://email.mg-d1.substack.com/c/eJyUks1uozwUhq_G7IjsY8cJCxakFH30m5Cmk7aT… > > > > > > > > < > https://email.mg-d1.substack.com/c/eJxckk1vozAQhn-NuSXyB5Bw4AClaOluSNOm7aaX… > > > > > > > > < > https://email.mg-d1.substack.com/c/eJxck01zozgYhH8NviWlD3DMwQdjgwNj5JgAMlxS… > > > > > > > > READ IN APP > > > < > https://email.mg-d1.substack.com/c/eJxskM1uIyEQhJ8GbmM1DbaZA4eVrHkNi58em90Z… > > > > > > > > > > > < > https://email.mg-d1.substack.com/c/eJxckL2O1DAURp_G6Ty6vr7O2oULYDdigkAICiQa… > >this > > > won’t hurt at all, promise > > > > > > What exactly is a CISO, anyway? > > > > > > I see CISO job ads asking for people’s GitHub handles, but you’re not > > > hiring a developer, and you're not hiring an engineering manager, > you're > > > hiring a CISO. > > > > > > Thanks for reading Cyber Cyber Cyber Cyber! Subscribe for free to > receive > > > new posts and support my work. > > > > > > Pledge your support > > > < > https://email.mg-d1.substack.com/c/eJxcU812qkwQfBrY6ZkfUFmwMBIj8wnGyMffJgdm… > > > > > > > > Security engineering is not about writing code, so even if you were > hiring > > > an Security Engineering Manager you still wouldn’t want to be measuring > > > candidates based on the code they write. > > > > > > So if a CISO isn’t just a weird form of security engineering manager, > then > > > what exactly do we do all day long, anyway? > > > > > > What’s the recipe for a CISO? > > > One bushel of technical systems knowledge > > > > > > How do things work? You can’t secure a system if you don’t understand > the > > > system at least as well as attackers. From my point of view, that > means a > > > good CISO is much more likely to come out of traditional IT or even a > > > DevSecOps role than from a developer role. Developers are generally > > > laser-focused on a specific tech stack—deep and narrow—but a CISO > needs to > > > spread themselves thin across everyone and everything in their > org—shallow > > > but broad. > > > a demijohn of people, people, people > > > > > > Not just technology, but also process and people. Because the human > > > systems you are defending are not technical. CISOs are focused on risk > > > management, and the way you manage risk—since risk mitigation is almost > > > always part of risk management—is to change things. To change the way > > > people do things. In other words, change management. But people hate > > > change! Oh my lord do people hate change. So exercising diplomacy and > > > influence across an org is key to securing an org. That’s not a 133t > > > supercoder job. > > > a peck of security mindset > > > > > > No one can be successful in any security role without the security > > > mindset. This is the adversarial thinking that distinguishes a builder > from > > > a breaker, and it’s the raw material I look for when interviewing > > > candidates. You can teach technical skills, but you can’t teach > adversarial > > > thinking to someone who lacks the knack. It’s a raw talent that I’ve > > > discovered in people both technical and non-technical. A CISO unable to > > > think creatively about adversaries—whether the North Korean military, a > > > ransomware gang, or the Irish Data Protection Authority—is not going > to be > > > effective in their role. > > > two liters of leadership ability > > > > > > A one-man CISO is just a phony title. Ultimately a company of any size > > > that needs a CISO is going to need a security team for the CISO to > lead. > > > But that means the CISO needs to be an effective team leader who knows > how > > > to delegate, to motivate, to discipline—to get the most out of their > team > > > for the benefit of their employer. This includes leading on both > security > > > engineering (managing real securiy risk) as well as security compliance > > > (working with Legal to meet regulatory risk appetite, acquiring > security > > > certifications like ISO 27001 to enable the business to close deals, > etc). > > > a barrel of business mindset > > > > > > It is a tempting but fatal rookie error in security to be an absolutist > > > about security. This is unhelpful and makes you a bad CISO. A CISO is > not > > > just a technical engineering manager—a CISO is a business executive > whose > > > job is to working closely with the CEO and Board of Directors to > balance > > > risk and opportunity to meet business goals. A CISO is not a high > priest of > > > security trying to achieve perfection or a Cassandra warning of doom. > Risk > > > is part of doing business, and security risk is part of doing business. > > > Making sure the business understand that risk, and helping the > business to > > > choose between accepting risk or spending money to mitigate that risk, > is > > > the fundamental service the CISO provides. > > > a heaping tablespoonful of lawyer > > > > > > I am not a lawyer and I don’t play one on TV. But I need a solid grasp > of > > > the law in order to do my job. As I explained to a disbelieving > colleague—a > > > software engineering manager—security straddles the fence between > > > Engineering and Legal. Legal and regulatory risk are a major part of > my job > > > as a CISO. When my adversaries aren’t just criminal hackers but > government > > > regulators, I better understand the regulations that we aim to either > > > comply with (or, as an executive decision involving the General > Counsel, to > > > not comply with because the risk of a regulatory fine is so low). > > > a pinch of accountant > > > > > > You can either accept risk or spend money to mitigate risk. That means > you > > > need a solid beancounter mentality to be effective as a CISO. How much > > > money should we spend? What's the cost/benefit analysis of that spend? > > > (What's your Security ROI?) Are you spending money wisely, and being a > good > > > steward of company funds? > > > a megaphone of hostage negotiator > > > > > > Negotiating contracts with security vendors sometimes feels like a > hostage > > > negotiation. "Pay us this crazy money for a substandard product, or the > > > hostage gets it." In this case my employer is the hostage. It’s not > > > racketeering but it sometimes feels like it! Being able to go to the > mat > > > with vendors and tear into their offering to get a better price is a > > > crucial skill for a CISO. It’s not enough to just mitigate security > risk, > > > you should be optimizing for cost as well. > > > Recipe > > > > > > Throw all the ingredients into a blender. Puree on low for twenty > years or > > > so. Pour into a suit hoodie (half suit, half hoodie) and serve with a > > > heaping side order of ambiguity. > > > > > > Thanks for reading Cyber Cyber Cyber Cyber! Subscribe for free to > receive > > > new posts and support my work. > > > > > > Pledge your support > > > < > https://email.mg-d1.substack.com/c/eJxcU812qkwQfBrY6ZkfUFmwMBIj8wnGyMffJgdm… > > > > > > > > Cyber Cyber Cyber Cyber is free today. But if you enjoyed this post, > you > > > can tell Cyber Cyber Cyber Cyber that their writing is valuable by > pledging > > > a future subscription. You won't be charged unless they enable > payments. > > > > > > Pledge your support > > > < > https://email.mg-d1.substack.com/c/eJxck02TsjgUhX8N7LTyAbywYGFL25IRfG0ZvjZd… > > > > > > > > Like > > > < > https://email.mg-d1.substack.com/c/eJxcksFuozAQhp_G3BLZY6DhwCFbkpY2EKVKs8le… > > > > > Comment > > > < > https://email.mg-d1.substack.com/c/eJyUks1uozwUhq_G7IjsY8cJCxakFH30m5Cmk7aT… > > > > > Restack > > > < > https://email.mg-d1.substack.com/c/eJxck01zozgYhH8NviWlD3DMwQdjgwNj5JgAMlxS… > > > > > > > > > > > © 2024 J.M. Porup > > > 548 Market Street PMB 72296, San Francisco, CA 94104 > > > Unsubscribe > > > < > https://email.mg-d1.substack.com/c/eJxck7mSqzgUhp_Gzm6XFrBNQOAFuqEsuGCxJreQ… > > > > > > > > [image: Get the app] > > > < > https://email.mg-d1.substack.com/c/eJxckLuO1TAURb_G7hzZx4_EhQtgJuIGgRAUSDTI… > >[image: > > > Start writing] > > > < > https://email.mg-d1.substack.com/c/eJxckstyskoUhZ8GZrG6d4PaAwZGBbF-SPQoCJNU… > > > > > >

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Kiva.org Financial Inclusion Video
by Gunnar Larson 04 Mar '24

04 Mar '24

Kiva.org Financial Inclusion Video: https://www.instagram.com/reel/C3_Ra3LyQJm/?igsh=MXhsMjgwczc3bXl1dg==

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Memo #4 - Goldman Sachs Deferred Prosecution Agreement
by Gunnar Larson 04 Mar '24

04 Mar '24

https://docs.google.com/document/d/1ajVVx6NGB9wd2GDXfLRftf0RVFpqjl8WWITvdNV… 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

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