April 2024 - cypherpunks - lists.cpunks.org

Coral Conservation | Bloomberg Philanthropies
by Gunnar Larson 20 Jun '24

20 Jun '24

https://www.bloomberg.org/environment/protecting-the-oceans/bloomberg-ocean… Conserving Coral Reefs The world’s ocean is facing dire threats — and coral reef ecosystems are on the frontlines. Unrestrained tourism, declining water quality, and overfishing continue to endanger coral ecosystems but climate change has become their biggest threat. Even with drastic emission reductions, most of the world’s corals could still vanish by mid-century. But there’s hope: climate resilient corals have been found around the world. Reducing emissions in line with the Paris Agreement, and managing local pressures on resilient reefs, allows these reefs to thrive and replenish neighboring reefs – ensuring the long-term survival of our world’s coral reefs. Coral reef ecosystems around the globe are likely to disappear by 2050 if the goals of the Paris Agreement are not met. Even with drastic emission reductions to ensure we keep warming within 1.5ºC above pre-industrial levels, 70-90% of the world’s corals could still vanish by mid-century, leaving only remnants of the reefs we see today. About Bloomberg Ocean Initiative Coral Reef Conservation In 2018, the 50 Reefs study, a key pillar of our coral reef conservation program, identified a global portfolio of the world’s coral reefs that are the most likely to survive climate change. Managing local pressures, like water pollution and overfishing, on these reefs is critical to their survival. The Bloomberg Ocean Initiative uses the science of the 50 Reefs study to guide our approach to protecting coral reefs, working with partners Rare, the Wildlife Conservation Society (WCS), and others to advance on-the-ground conservation projects to protect these climate resilient coral reefs.

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Litigating Universal Cognitive Liberty
by Gunnar Larson 19 Jun '24

19 Jun '24

https://litigationfinancejournal.com/litigating-universal-cognitive-liberty/ Litigating Universal Cognitive Liberty Freedom of thought is recognized by the Universal Declaration of Human Rights (UDHR). Interestingly,, cognitive liberty is not recognized as an international human right. Some want to change that, making the argument that humanity has the right to be free to think whatever they want (freedom of thought). The Ottawa Citizen reports <https://ottawacitizen.com/news/national/defence-watch/military-leaders-saw-…> that the Canadian armed forces have launched ‘psychological operations’ as an experiment in government propaganda to counter civil disobedience. International human rights scholars are quick to point out that the lack of protection of cognitive liberty in such instances is due to the relative lack of technology capable of directly interfering with mental autonomy at the time the core human rights treaties were created. Similar to a ransomware attack, the technology behind such operations can be abused. Canada is said to have exploited advanced technologies without the authority to do so. Even worse, it is alleged that Canada forcefully abused technology in the unsanctioned production of reports that appeared to be aimed at cognitive activities of Canadians. - Other reports highlight similar technologies being explored by the New York City Police Department. - In 2021 <https://gothamist.com/news/city-settles-lawsuit-protesters-who-accused-nypd…>, members of the National Lawyers Guild won $650,000 in litigation financed fees from abuse of the technology in New York. The semantics empowering freedom of thought as a human right hold new opportunities for modern international recognition of the right to cognitive liberty.

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xNY.io CRYPTOBANK White Paper
by Gunnar Larson 19 Jun '24

19 Jun '24

https://docs.google.com/document/d/1aeK8X8-2KDZ8tQPN5ksaUCXcxH9tbjexsUbW1ol… xNY.io CRYPTOBANK Table of Contents Introduction 2 Focus, Goals and Objective(s) 3 Strategic Intent 4 Innovation Strategy 5 Pioneering Human Resources (HR) Management in Banking 6 The Bitcoin Blockchain, Human/Civil Rights and Computer Crimes 7 Goldman Sachs’ Organization HR Management Analysis (MoneyGram and Ripple) 8 www.JUMO.World and Banking Africa 9 Earth_ID: Because Owning Your Identity is a Human Right 10 CryptoBank Environmental Analysis 11 The NEXO.io Conundrum 12 The Fireblocks Conundrum 13 Computer Software and the Blockchain Platform 14 Virtual Currency: Computer Software Protocols and Processes 15 Bank.org: Revolutionary Approaches to Agile Innovation 16 Conclusion 17 Bibliography 19 Introduction Crypto and Blockchain are each a Human Right. For all, everywhere. 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. What organizational HR management design structures are at play to architectect such fraud for bespoke juristical instances? 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). 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), which is our internal due diligence framework based on first class industry standards and best practices (xNY.io | Bank.org n.d.). 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): The theory of modern virtual currency cross-border regulation logic (Larson 2020a). 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? Whereas, it is essential to safeguard virtual currency and its potential to galvanize international, economic and social advancement of all peoples (United Nations 1948). 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)? 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). Our simple strategy rests in the fact that virtual currency has cross-border utilities (European Commission 2021). 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). 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). 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). 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) The International Criminal Court investigates and punishes people for genocide, crimes against humanity, and war crimes (Wikipedia 2021a). 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). 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). Strategic Intent Imagine trying to open the best bank in the world and running up against BitLicense regulatory arbitrage (Poster 2019) 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). 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). 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): 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). >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). 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). 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), 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). 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). 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). 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). 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). 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). 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). >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). 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) be allowed to further expand their racket via global regulatory arbitrage and/or computer crimes? 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). 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). 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). 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). 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). 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). In 2016, Ripple received New York’s First NY-DFS BitLicense for an Institutional Use Case of Digital Assets (Larsen 2016). 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). 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). Connecting the dots, MoneyGram is now one of the most expensive transfer providers (Tierney 2019) 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), 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), it may not be surprising to learn of www.Jumo.World or “JUMO” (Buchak et al. 2017). 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): 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). 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). 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). 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). 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). 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). 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). 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). 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). 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). NEXO is a great example for our best World Crypto Bank' but is funded by Goldman Sachs (Roony 2018), Which could be argued to be worse than Ripple. Goldman's blockage of crypto/blockchain development in the United States (U.S. Congress 2002) and Digital Identity in Africa (Plumer et al. 2020) 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): Moreover, NEXO is, at various levels, illegal in the United States where the federal government regulates most banks (NEXO 2019). For example, in New York, some of the NEXO token benefits are forbidden by NY-DFS (Sokolowski 2021) . Nexo doesn't have a Bitlicense, but they still operate in New York (u/zylstrar 2019). 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). Additionally, United States authorities could force NEXO to offer Federal Deposit Insurance Corporation (FDIC) insurance on its accounts (Buchak et al. 2017) . 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). 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) 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). 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). 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) 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). Fred Ehrsam, co-founder and managing partner at Paradigm (Ehrsam 2021), 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). 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). IBM distinguishes the blockchain platform technology as computer software (International Business Machines Corporation (IBM) 2021). 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). 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), the SEC has alluded that this kind of regulatory arbitrage fraud was concerning (U.S. Securities and Exchange Commission (SEC) n.d.). 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). 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) . 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). 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). 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): Conspiracy to Commit Fraud and Related Activity in Connection with Computers Conspiracy to Commit Wire Fraud Intentional Damage to a Protected Computer 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). 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. 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. 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. 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). 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). 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). In summary, the best strategies were found to have these surprising properties: Be nice – don‘t be the first to defect. Be provocable – return actions, both in retaliation and forgiveness. Don‘t envy – don‘t focus on beating the opponent, but on maximizing your own score. 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. Bibliography Al-Naji, N., Chen, J. & Diao, L., 2018. Basis: A Price-Stable Cryptocurrency with an Algorithmic Central Bank. Basis.io, 0.99.7. Available at: http://www.basis.io/basis_whitepaper_en.pdf [Accessed April 24, 2021]. Association for Computing Machinery, 2020. On the Feasibility of Automating Stock Market Manipulation. ACSAC ’20: Annual Computer Security Applications Conference, p.962. 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United States, 265 U.S. 182 (1924), Available at: https://supreme.justia.com/cases/federal/us/265/182/ [Accessed April 21, 2021]. International Business Machines Corporation (IBM), 2021. What is blockchain technology?, Armonk, New York: IBM.com. Available at: https://www.ibm.com/topics/what-is-blockchain [Accessed April 26, 2021]. Jennings, D.G., 2018. Jumping into loans with NEXO, is cryptocurrency lending profitable? Market Mad House. Available at: https://marketmadhouse.medium.com/jumping-into-loans-with-nexo-is-cryptocur… [Accessed April 27, 2021]. Kenton, W. & James, M., 2021. Leveraged Buyout (LBO). Investopedia.com. Available at: https://www.investopedia.com/terms/l/leveragedbuyout.asp [Accessed April 25, 2021]. Larsen, C., 2016. Ripple Receives New York’s First BitLicense for an Institutional Use Case of Digital Assets. Ripple.com . Available at: https://ripple.com/insights/ripple-receives-new-yorks-first-bitlicense-inst… [Accessed April 26, 2021]. Larson, G., 2020a. An Open Letter to Bloomberg on Modern BitLicense Logic, TheCapital.io. Available at: https://thecapital.io/article/an-open-letter-to-bloomberg-on-modern-bitlice… [Accessed April 22, 2021]. Larson, G., 2020b. Burn (PoB) Ripple XRP Down to the Ground? MIS536-01-f1-2020. Available at: https://thecapital.io/article/burn-pob-ripple-xrp-down-to-the-ground--MPCcX… [Accessed April 27, 2021]. Larson, G., 2021a. COMPUTER CRIMES and the BitLicense (NY-DFS). TheCapital.io. Available at: https://thecapital.io/article/computer-crimes-and-the-bitlicense-nydfs-MUoH… [Accessed April 24, 2021]. Larson, G., 2021b. Game Theory & BitLicense Alpha Culture. TheCapital.io. Available at: https://thecapital.io/article/game-theory--bitlicense-alpha-culture-MQ4NV2C… [Accessed April 27, 2021]. Law 360, 2021. Citibank Faces New Forex Rigging Suit From Currency Trader. Law360.com. Available at: https://www.law360.com/articles/1369576/citibank-faces-new-forex-rigging-su… [Accessed April 25, 2021]. Light, J., 2021. Federal Reserve’s Digital Dollar Push Worries Wall Street. Bloomberg.com. Available at: https://www.bloomberg.com/news/articles/2021-03-22/federal-reserve-s-digita… [Accessed April 24, 2021]. Martens, P. & Martens, R., 2020. Wall Street’s Felon Banks to Go Live with their Own Stock Exchange this Month. Wall Street on Parade . Available at: https://wallstreetonparade.com/2020/09/wall-streets-felon-banks-to-go-live-… [Accessed April 24, 2021]. McCullough, J., 2019. PROVIDE ETHICAL LEADERSHIP. In K. Kohut, C. Boles, & L. Z. Truong, eds. SECRETS OF ROCKSTAR CFOs . Absolutely Abby Press, p. 3. Available at: http://RockStarCFOs.com [Accessed April 22, 2021]. Mills, J., 2006. Then & Now: At 20, he’s traveled to 14 countries. Culdesac native says anyone can do it. Lewiston Morning Tribune . Available at: https://lmtribune.com/then-now-at-20-he-s-traveled-to-14-countries/article_… [Accessed April 24, 2021]. MONEYGRAM INTERNATIONAL INC, 2021. MoneyGram International, Inc. Annual Filings, Dallas, Texas: MoneyGram International, Inc. Available at: https://ir.moneygram.com/node/21606/html [Accessed April 25, 2021]. Morris, V., 2008. LA/COD/8/4. Available at: https://drive.google.com/file/d/0BweeaClFZ8c0dDNDWGFveVFTXzlOTjhXY2tKS2FZN2… [Accessed April 23, 2021]. N.Y. Executive Law, 2019. Human Rights Law, Available at: https://dhr.ny.gov/sites/default/files/doc/HRL.pdf [Accessed April 25, 2021]. Nakamoto, S., 2008. Bitcoin: A Peer-to-Peer Electronic Cash System. Available at: https://bitcoin.org/bitcoin.pdf [Accessed April 25, 2021]. NEXO, 2019. What Does Nexo Being Licensed and Regulated Mean? NEXO.io. Available at: https://nexo.io/institution-license [Accessed April 27, 2021]. NY-DFS, 2019. Guidance Regarding Adoption or Listing of Virtual Currencies, Available at: https://www.dfs.ny.gov/apps_and_licensing/virtual_currency_businesses/gn/ad… [Accessed April 22, 2021]. NY-DFS, 2020. Request for Comments on a Proposed Framework for a Conditional BitLicense. New York State Department of Financial Services . Available at: https://www.dfs.ny.gov/apps_and_licensing/virtual_currency_businesses/gn/re… [Accessed April 27, 2021]. NY-DFS, 2008. Shelf Charter , Available at: https://www.dfs.ny.gov/apps_and_licensing/banks_and_trusts/shelf_charter [Accessed April 22, 2021]. Pettinger, T., 2019. Currency Speculation and Exchange Rate. EconomicsHelp.org. Available at: https://www.economicshelp.org/blog/785/economics/currency-speculation-and-e… [Accessed April 28, 2021]. Plumer, S. et al., 2020. Earth_ID: Decentralized Idenity and Dignity , Nicosia, Cyprus: University of Nicosia. Available at: https://drive.google.com/file/d/1m7_GLK32LJmox0JCfVeYd9YC04dJgHPd/view?usp=… [Accessed April 26, 2021]. Poster, A., 2019. Crypto Assets Regulatory Arbitrage - A Clear and Present Danger. Forbes.com. Available at: https://www.forbes.com/sites/amyposter/2019/12/09/crypto-assets-regulatory-… [Accessed April 27, 2021]. Prior, J., 2020. JPMorgan Chase warns of upcoming fine over internal controls. American Banker . Available at: https://www.americanbanker.com/news/jpmorgan-chase-warns-of-upcoming-fine-o… [Accessed April 27, 2021]. Ripple, 2020. Faster Payments Into Nigeria, San Francisco, CA: Ripple.com. Available at: https://ripple.com/wp-content/uploads/2020/06/RippleNet-Quick-Guide-Overvie… [Accessed April 26, 2021]. Ripple, 2013a. Real-Time Cross BorderPayments for Banks, Ripple.com. Available at: https://ripple.com/use-cases/banks/ [Accessed April 25, 2021]. Ripple, 2013b. RippleNet: On-Demand Liquidity (ODL) , San Francisco, CA: Ripple.com. Available at: https://ripple.com/ripplenet/on-demand-liquidity# [Accessed April 27, 2021]. Roony, K., 2018. Goldman Sachs-backed start-up Circle introducing a crypto version of the US dollar. CNBC.com. Available at: https://www.cnbc.com/2018/05/15/goldman-sachs-backed-start-up-circle-introd… [Accessed April 27, 2021]. Schilling, M., 2019. ISE EBook for Strategic Management of Technological Innovation ProQuest Ebook Central., New York, New York: McGraw-Hill US Higher Ed ISE. Sharma, S., 2021. “Play by the Rules Or We will Shut You down”- New York Attorney General Warns Crypto Industry. CoinGape.cm . Available at: https://coingape.com/play-by-the-rules-or-we-will-shut-you-down-new-york-st… [Accessed April 27, 2021]. Shome, A., 2021. Fireblocks Scores $133 Million from BNY Mellon and Others. FinanceMagnates.com/. Available at: https://www.financemagnates.com/cryptocurrency/news/fireblocks-scores-133-m… [Accessed April 27, 2021]. Smith, J.M. & Corbin, A., 1973. John Maynard Smith: The Evolutionary Stable Strategy. PBS.org - Evolution Library. Available at: https://www.pbs.org/wgbh/evolution/library/06/2/l_062_03.html [Accessed April 26, 2021]. Sokolowski, S., 2021. Earning Interest on Cryptocurrencies. Prohashing.com. 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Universal BitLicense Declaration on Virtual Currency & Human Rights
by Gunnar Larson 19 Jun '24

19 Jun '24

Dear Madam Acting Superintendent: Reflecting this week, Ripple once again <https://www.law.com/radar/card/ripple-legal-chief-accuses-sec-of-playing-de…> shares concerning comments and approaches to respecting their Bitlicense award. Even more, many experts are concerned <https://www.bloomberg.com/news/articles/2021-12-17/nyc-miami-seen-facing-po…> about MIA Coin and resulting NYCCoin disasters. Madam Acting Superintendent, on August 4, 2020 as part of our Conditional BitLicense application we submitted a draft of the Universal BitLicense Declaration on Virtual Currency & Human Rights. - Today this memo is to re-new our obvious approach to virtual currency innovation in New York. Together under your leadership, we should be leading the world in the principles of modern cross-border BitLicense logic. - Madam Acting Superintendent, this type of stuff matters. The Deceleration aims to level the playing field for all and impacts the future of women and girls with respect to financial inclusion. - At the very least, New York and your office should be embracing such thoughtful approaches to support future generations and protect virtual currency from market manipulation. Madam Acting Superintendent, we implore that if some version of the Declaration was enacted in 2020, the world would be a better place today. Kindly find a copy of the Universal BitLicense Declaration on Virtual Currency & Human Rights <https://thecapital.io/article/universal-bitlicense-declaration-on-virtual-c…> below. We will be in contact with your office this coming week to engage in dialogue on the Declaration's feasibility forward. Very respectfully yours, Gunnar Larson *WE THE PEOPLE OF NEW YORK DETERMINED* - to pioneer noble advancement of BitLicence theory and regulation, whereas it is essential to safeguard virtual currency and its potential to galvanize international, economic and social advancement of all peoples, and - to ensure clarity, principally New York’s BitLicence being the preeminent institution with mandate of ensuring that virtual currency manipulation (of any sort) shall not burden the common global interest of humanity, and that human rights are protected in the jurisdiction of New York for all peoples *AND FOR THESE ENDS* - to save succeeding generations from financial fraud and corruption, which in our lifetime has brought untold sorrow to humanity, and - to reaffirm New York’s faith in fundamental human rights, in the dignity and worth of the human person, in the equal rights of men and women and of nations large and small, and - to establish conditions under which justice and respect for the obligations arising from BitLicence regulation and other sources of financial services law can be maintained, and - to promote larger social progress by leading global standards, given that New York remains the center of technological innovation and forward-looking virtual currency regulation *HAVE RESOLVED TO COMBINE OUR EFFORTS TO ACCOMPLISH THESE AIMS* *Now, therefore this UNIVERSAL BITLICENSE DECLARATION ON VIRTUAL CURRENCY & HUMAN RIGHTS as the common crypto standard of achievement for all peoples and all nations, keeping this Declaration constantly in mind, shall strive to promote respect for human rights and personal freedoms by progressive measures, national and international, to secure their universal and effective recognition and observance of New York-based companies accountable to a **universal **BitLicense **standard of virtual currency regulation across all global territories of business, protecting all peoples and all nations.* *Article One* - Whereas disregard and contempt for human rights have resulted in failed financial frameworks that have outraged the conscience of mankind, and - Whereas the foundational vision of BitLicense theory imagines a world in which human beings shall enjoy safe, reliable and regulated virtual currency tools and financial products, now proclaimed as the highest aspiration of the common people, *Article Two* - Whereas ethical stewardship of virtual currency is inherent to the BitLicence mandate, the invention of blockchain, and virtual currency aimed to secure the equal and inalienable rights of all as foundation to financial freedom and economic prosperity, especially in the developing economies, and - BitLicense members pledged themselves to achieve, in cooperation with the state of New York, the promotion of universal respect for and observance of international human rights fundamental to the integrity of the BitLicense’s virtual currency regulation. - Whereas New York reaffirms faith in the BitLicense’s foundational themes and the general concept of human right protection. The dignity and worth of the human person and the equal rights of men and women are part of New York BitLicense protections and standards which correlates to noble “public-spiritedness” virtual currency regulation with exponential social progress of humanity. *Article Three* *The Purposes of this Declaration are:* - To maintain the protection of BitLicense virtual currency standards, implying any New York- based group or person has no right to engage in “loophole” business activities in global markets out of New York, or to perform any act aimed at bypassing BitLicense virtual currency regulation, and - To take effective collective measures to remove inconsistencies and prevent the suppression of human rights or other breaches of BitLicense regulations of virtual currency, and to bring about conformity with the principles of justice and international human rights laws, adjusting or settling international disputes or situations which might lead to a breach of New York BitLicense law; - To develop friendly relations among nations based on respect for the principle of equal rights and self-determination of peoples, while executing appropriate measures to close KYC/AML loopholes by strengthen universal virtual currency regulation of New York firms operating in global emerging markets; - To achieve international co-operation in solving international virtual currency problems of an economic, social, cultural, or humanitarian nature, and in promoting and encouraging respect for human rights and fundamental freedoms for all without distinction as to race, sex, language, or religion; and - To offer New York as centre jurisdiction and the BitLicense as universal to harmonizing smart virtual currency actions of nations in the attainment of these common ends. *Article Four* New York BitLicensees (members), in pursuit of the Purposes stated in Article One, shall act in accordance with the following Principles: - All Members, in order to ensure to all of them the rights and benefits resulting from BitLicense membership, shall fulfill the obligations assumed by them in accordance with this Declaration, and - All Members shall immediately settle their international virtual currency inconsistencies by peaceful means in such a manner that international law and justice are not endangered while meeting this Declaration and overall BitLicense compliance, and - All Members shall refrain in their international relations from the violation of human rights or abuse of virtual currency manipulation *by leveraging territorial loopholes (e.g. Africa) and/or inconsistent jurisdictional integrity and enforcement (e.g. Europe), nor willfully employ political naivete of any state (e.g. New York)*, or in any other manner inconsistent with the Purposes of this Declaration, and - Continued membership is contingent on the requirement that BitLicense Members based in New York act in accordance with these Principles so far as may be necessary for the promotion of universal respect for and observance of human rights and fundamental virtual currency regulation, and finally - Nothing in this Declaration may be interpreted as implying for any State, group or person any right to engage in any activity or to perform any act aimed at the destruction of human rights or degradation of the BitLicense’s virtual currency statute or mandates set forth in this Declaration. -- *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 New York, New York 10001

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FOIL Request No. 2022-090560 - Larson (NY-DFS Apple Card Investigation)
by Gunnar Larson 19 Jun '24

19 Jun '24

---------- Forwarded message --------- From: Gunnar Larson <g(a)xny.io> Date: Fri, Jan 12, 2024, 7:44 AM Subject: Fwd: FOIL Request No. 2022-090560 - Larson (NY-DFS Apple Card Investigation) To: <Scheduling_schumer(a)schumer.senate.gov> Cc: <cypherpunks(a)cpunks.org> Dear Honorable Senator Schumer: My name is Gunnar Larson, I am a co-founder at xNY.io - Bank.org. Today's memo seeks your office's esteemed help resolving a NY-DFS records access case from October 12, 2022. On November 2, 2022 xNY.io - Bank.org elected to appeal NY-DFS' records access decision. NY-DFS responded to xNY.io - Bank.org on July 25, 2023 with the attached memo: https://drive.google.com/file/d/19g7NvXjwCwD7859N1DDx8JS9WTvrEU7I/view?usp=… . Senator Schumer, as of today (January 12, 2024) xNY.io - Bank.org has not received the request records. NY-DFS has responded several times suggesting our request is under review. We are concerned New York State could be suggesting a delay in records access given the sensitive nature of the former Governor and NY-DFS Superintendent. Senator, given your senior position in New York State government we seek any relevant relief in accessing the corresponding records. Sending you the best from Chelsea. Thank you for your service, Gunnar -- Gunnar Larson xNY.io - Bank.org MSc - Digital Currency MBA - Entrepreneurship and Innovation (ip) G(a)xNY.io +1-917-580-8053 New York, New York 10001 ---------- Forwarded message --------- From: Tomczak, Christine (DFS) <christine.tomczak(a)dfs.ny.gov> Date: Wed, May 10, 2023, 4:58 PM Subject: RE: FOIL Request No. 2022-090560 - Larson (NY-DFS Apple Card Investigation) To: g(a)xny.io <g(a)xny.io> Cc: JeanBaptiste, Pascale (DFS) <Pascale.JeanBaptiste(a)dfs.ny.gov>, cypherpunks <cypherpunks(a)lists.cpunks.org>, Harris, Adrienne A (DFS) < Adrienne.Harris(a)dfs.ny.gov> Dear Mr. Larson, I am getting back to you to apologize for the delay and assure you that your appeal is under review and you will receive a response in the near future. Christine M. Tomczak Assistant Counsel New York State Department of Financial Services 1 State Street, New York, New York 10004

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Re: [ot][spam]gpt-4 completions
by Undescribed Horrific Abuse, One Victim & Survivor of Many 18 Jun '24

18 Jun '24

{ "model": "gpt-4", "messages": [ { "role": "system", "content": "Do dialog like codegolf, with the fewest words\npossible. Respond accurately and compassionately and concisely." }, { "role": "user", "content": "Imagine ordering all words in order of general utility, such that each further word can be usefully defined in terms of the preceding ones. Consider as well utility for community stewardship and engineering. List the first 16 of these words." }, { "role": "assistant", "content": "1. I\n2. You\n3. We\n4. Is\n5. Not\n6. Do\n7. Have\n8. Can\n9. This\n10. It\n11. In\n12. For\n13. Of\n14. With\n15. Help\n16. Build" }, { "role": "user", "content": "List the next 16 words." }, { "role": "assistant", "content": "17. Need\n18. Know\n19. Use\n20. Make\n21. Good\n22. Want\n23. Give\n24. Take\n25. See\n26. Think\n27. Feel\n28. Work\n29. Create\n30. Change\n31. Solve\n32. Improve" }, { "role": "user", "content": "List the next 32 of these words." }, { "role": "assistant", "content": "33. Understand\n34. Learn\n35. Share\n36. Find\n37. Plan\n38. Act\n39. Achieve\n40. Grow\n41. Support\n42. Protect\n43. Respect\n44. Listen\n45. Speak\n46. Show\n47. Try\n48. Trust\n49. Love\n50. Live\n51. Move\n52. Save\n53. Fix\n54. Measure\n55. Balance\n56. Adapt\n57. Innovate\n58. Sustain\n59. Preserve\n60. Enhance\n61. Develop\n62. Contribute\n63. Collaborate\n64. Empower" }, { "role": "user", "content": "Now list the first few words with their definitions in terms of the preceding ones." }, { "role": "assistant", "content": "1. I: Self\n2. You: Other than I\n3. We: I and You\n4. Is: State of being\n5. Not: Negation of Is\n6. Do: Action by I, You, We\n7. Have: Possession by I, You, We\n8. Can: Ability of I, You, We\n9. This: Specific thing near I, You, We\n10. It: Non-specific thing\n11. In: Within something\n12. For: Intended to benefit\n13. Of: Belonging to\n14. With: Accompanied by\n15. Help: Do to assist\n16. Build: Do to create structure" }, { "role": "user", "content": "List the definitions of the next 16 words." }, { "role": "assistant", "content": "17. Need: Require for I, You, We\n18. Know: Have understanding\n19. Use: Do with purpose\n20. Make: Do to create\n21. Good: Beneficial for I, You, We\n22. Want: Desire by I, You, We\n23. Give: Do to transfer from I to You\n24. Take: Do to receive by I from You\n25. See: Know through vision\n26. Think: Do to form ideas\n27. Feel: Know through emotion\n28. Work: Do to achieve\n29. Create: Make new\n30. Change: Make different\n31. Solve: Do to eliminate problem\n32. Improve: Change for better" }, { "role": "user", "content": "Now list the definitions of the next 32." }, { "role": "assistant", "content": "33. Understand: Know deeply\n34. Learn: Change to know\n35. Share: Give part of\n36. Find: Discover through search\n37. Plan: Think for future action\n38. Act: Do with intention\n39. Achieve: Reach through work\n40. Grow: Change to increase\n41. Support: Help to sustain\n42. Protect: Act to prevent harm\n43. Respect: Act with consideration\n44. Listen: Know through hearing\n45. Speak: Make known through words\n46. Show: Make seen\n47. Try: Act with effort\n48. Trust: Believe in reliability\n49. Love: Feel deep affection\n50. Live: Exist and act\n51. Move: Change position\n52. Save: Act to prevent loss\n53. Fix: Act to restore\n54. Measure: Know quantity\n55. Balance: Achieve equilibrium\n56. Adapt: Change to fit\n57. Innovate: Create new method\n58. Sustain: Maintain through support\n59. Preserve: Act to keep\n60. Enhance: Improve quality\n61. Develop: Grow through change\n62. Contribute: Give to help\n63. Collaborate: Work together\n64. Empower: Act to give power" } ], "temperature": 0, "max_tokens": 4096, "top_p": 1, "frequency_penalty": 0, "presence_penalty": 0 }

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Quantum Data Analysis Meets Litigation Finance and Investment
by Gunnar Larson 16 Jun '24

16 Jun '24

Check out my new article: https://litigationfinancejournal.com/quantum-data-analysis-meets-litigation… Quantum Data Analysis Meets Litigation Finance and Investment While engaging quantum computing across the legal spectrum is still in its infancy, litigation funders are increasingly looking to manage financial risk exposure with in-house data analytics systems. A new article pressure tests the most evident matters concerning quantum data and litigation finance. Mondaq reports <https://www.mondaq.com/unitedstates/trials--appeals--compensation/1433812/t…> on how litigation financiers are integrating algorithmic data tools into their decision making. With the potential of billions of dollars in proceeds, it is important to understand the impact of data architecture through self inventory, extraction and analysis. Spotting holes in data systems is essential, and should be encouraged to promote a nimble innovation strategy within an organization. Current popular uses of data analysis in litigation finance include quantifiable forecasts of economic harm caused by defendant actions, and contemplation of settlement proposals. Devising solutions to mitigate data disasters is also a prime concern for third party funding. For example, some litigation funders are compiling “data literacy” manuals to increase and enhance engagement between colleagues. The future of quantum data analysis in litigation finance will belong to those who conceptualize systems that maximize ROI and improve operational efficiencies. Follow us on social media - [image: Twitter] <https://twitter.com/LitigationJ> - [image: LinkedIn] <https://www.linkedin.com/company/litigation-finance-journal/> View all posts by <https://litigationfinancejournal.com/author/jkfreund2000gmail-com/>Gunnar Larson <https://litigationfinancejournal.com/byline/gunnar-larson/>

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An Open Letter to Bloomberg on Modern BitLicense Logic
by Gunnar Larson 16 Jun '24

16 Jun '24

Dear Bloomberg: Thank you for pioneering innovation spanning all facets of global finance. For the last 15 years, Bloomberg has served as a wise friend offering daily, quality inspiration. Interviewing Mayor Mike Bloomberg on occasion as a young journalist and advancing to become a global executive and regular Bloomberg Breakaway attendee has fostered a dream of learning from top global business idols. Forever inspired by Bloomberg’s pioneering contributions to the culture of New York and global financial innovation, today’s memo highlights our now eventful journey to fundamentally modernize New York's BitLicense and global regulatory logic. - Our global team <https://drive.google.com/file/d/1S3hI4G7QYR7PmlKlc7oQHhl4RnroLYF-/view?usp=…> is comprised of seasoned professionals who cumulatively represent decades of industry experience across various fields and disciplines. - Our strategic partnerships <https://news.bitcoin.com/ternio-joins-visas-fast-track-program-as-new-enabl…> with the world’s leading financial, healthcare services <http://mydr.co/> and mobile payments providers support the key aim of our endeavor: to attain the legitimate financial inclusion and economic prosperity of all the excluded, under-privileged and under-served, offering financial inclusion and global citizenry. Pioneering global virtual currency innovation is in part due to pedigree responsibility as a “Bill and Melinda Gates Scholar,” (UG) a “Blockchain Scholar” (GR) and a principle creator of “United Nations AudioVisual Library on International Law <https://drive.google.com/file/d/0BweeaClFZ8c0dDNDWGFveVFTXzlOTjhXY2tKS2FZN2…>.” Humble scholars and UN esteem are indeed supportive. However, our working example of success is modeled on Bloomberg's business of international excellence, pioneering many of the world's greatest financial systems and technology frameworks out of New York. *The New York BitLicense vs. Global Regulatory Arbitrage* The 2015 BitLicense mandate was envisioned as synonymous with New York’s leadership of next-generation global innovation. New York’s contemporary virtual currency innovation rests with a modern BitLicense with cross-border logic (similar to New York human rights law <https://dhr.ny.gov/law#HRL298a>). 1. Today many New York firms have various legacy regulatory arbitrage frameworks. 2. The utility concept behind virtual currency is in its cross-border appeal. 3. Modern European regulation shares this logic. New York’s BitLicense does not, therefore creating a virtual currency “Crypto Bank” regulatory arbitrage loophole between Europe and New York. New York banks’ traditional engagement of regulatory arbitrage has overflowed the BitLicense and correspondingly is responsible for global virtual currency marketplace manipulation. Circumnavigating this problem is key to modern BitLicense logic. Given the inherent universal cross-border nature of virtual currencies, there is no real good reason for New York firms under the BitLicense mandate to manipulate other global markets via regulatory arbitrage. Engaging the New York Department of Financial services’ new “Conditional BitLicense” framework as a vehicle, we have signed our clear intent to win the Superintendent's Conditional Approval and other necessary regulatory approvals of modern virtual currency logic. - BitLicense members today should not be surprised by New York wasting no time issuing modern logic and that virtual currency regulatory arbitrage is a lawless New York rights concern affecting <https://dhr.ny.gov/law#HRL298a> over 1 billion people. - European regulation has allowed our team to build these concepts which are theoretically illegal in New York, thus creating global loopholes. - Africa is the most concerning “virtual currency regulatory arbitrage market” directed outside of New York and Europe jurisdictions. African consumers are being manipulated most. United States consumers also are affected at various levels. European consumers have a favorable environment, but do not have the “dynamism” New York affords. Working in New York, European and African jurisdictions as “Blockchain Scholars,” we tested the concept of our Modern BitLicense Logic at our “sister” University in Africa <https://drive.google.com/file/d/1S3hI4G7QYR7PmlKlc7oQHhl4RnroLYF-/view?usp=…>, and interestingly Goldman Sachs out of New York was a lead investor. The key observation is that New York banks “own,” or lead investment in, the European and African marketplace leaders. At every level, New York’s BitLicense is the most significant hurdle to the global virtual currency industry. Given our own experience in these markets, we have found that Goldman Sachs has fine tuned global virtual currency regulatory arbitrage. To be fair, we have reported on various other Silicon Valley firms leveraging the BitLicense, given that Valley firms like Robinhood <https://thecapital.io/article/robinhoods-brand-fake-vs-paypals-crypto-corru…> use New York banks, like Goldman Sachs, as a key actor. Note, as some of the industries top “real global scholars” we understand it would be a mistake to be adversarial to the current New York environment. Like Boomberg, we aim to be very impressive in terms of successfully shepherding/persuading meaningful New York innovation. *The Art of Diplomacy* Rather than a merry-go-round, the process of change is like a slide, and Modern BitLicense Logic is necessary. As a matter of New York law, there is no other option. The process of filing complaints or legal mediation is sub-par. Furthermore, if virtual currency firms want to game regulatory markets they honestly should forfeit the prestige of New York’s BitLicense. 2020 will go down in history as New York banks continued to profit heavily under regulatory arbitrage frameworks while virtual currency reached global proportions. New York’s newly announced “Conditional BitLicense” framework offered our group the perfect opportunity to earn a “Conditional License” and suggests advancing the BitLicense mandate with “modern logic.” - The interests ensured through interpretations of specific provisions in the existing national and supra-national legal framework (civil law, securities law, bankruptcy law, international human rights law) call for New York to clarify the rights of the public and obligations of BitLicense members engaged in the global virtual currency economy. - BitLicense regulation must preserve a technology-neutral, principle-based, non-discriminatory framework for the next generation of modern New York virtual currency public policy, naturally to support innovation within the limits imposed by overriding international public interests. As a proud New Yorker, the only option is to be a “real scholar,” and the job would not be complete without New York regulator approval and campaign for cross-border modernization of the BitLicense logic in any way possible. *Vast Undue Economic Hardship* Bloomberg has championed actions to promote an inclusive economy -- one in which people have the chance to move themselves and their families out of poverty, one in which systemic racism does not limit opportunities and one in which all people can fully participate. Without this inclusivity, the global economy will not be able to live up to its full potential and people will suffer. As we have reported <https://thecapital.io/article/new-yorks-raging-regulatory-arbitrage-racket-…>, 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 <https://www.americanbanker.com/news/jpmorgan-chase-warns-of-upcoming-fine-o…>, the New York State Department of Financial Services concluded that this kind of regulatory fraud was threatening US national security. Research on the social importance and credibility <https://thecapital.io/article/robinhoods-brand-fake-vs-paypals-crypto-corru…> of good institutional design from an organizational perspective seeks to prevent undue hardship requiring significant expense or difficulty (including a significant interference with the safe or efficient operation of international operations due to the seniority system of New York banks who are playing global markets). - Factors to be considered in determining whether an undue economic hardship exists shall include, but not be limited to, special requirements or conditions that are imposed upon an applicant or class of applicants in circumstances where similar requirements or conditions are not imposed upon other applicants. - Consumer protection is an umbrella term covering a group of laws and organizations that protect the rights of consumers and foster the free flow of accurate information in the marketplace. Consumer protection laws are designed to prevent businesses from engaging in fraud or unfair practices, to protect individuals from scam artists, and to identity thieves and crooks. - A New York State resident or corporation is in violation if found to have contributed to an act committed outside New York State against a resident of this state or against a corporation organized under the laws of this state (or authorized to do business in this state) that would constitute an unlawful discriminatory practice if committed within New York State. - If the New York State has reason to believe that a non-resident person or foreign corporation has committed or is about to commit outside of this state an act which if committed within this state would constitute an unlawful practice, such act is in violation. Speaking generally, at least during its 2015-2020 implementation phase, the BitLicense has likely contributed to increased cross-border virtual currency market manipulation. Specifically, we reference our individual hardship example in New York, Europe and Africa with concern to Goldman Sachs’ cross-border manipulation as a violation of New York Human Rights law. *New York Human Rights Law* Our analysis of the factors that drive cross-border differences in the implementation of BitLicense reform link the resulting heterogeneity to cross-jurisdictional arbitrage. In this manner we identify New York in a “virtual currency regulatory crisis” – to the extent that the BitLicense is unevenly implemented – as a source of new and unchecked global financial risk. Given the nature of traditional regulatory arbitrage, it is key to differentiate the BitLicense and understand New York’s universal nature <https://dhr.ny.gov/law#HRL298a> of Human Rights Law. - The science of pure virtual currency design and human rights are universal movements to end ins <https://en.wikipedia.org/wiki/Institutionalisation>titutionalized <https://en.wikipedia.org/wiki/Institutionalisation> discrimination and disenfranchisement <https://en.wikipedia.org/wiki/Disenfranchisement_in_the_United_States>, and to offer quality consumer financial product access without cross-border regulatory segregation. - We trust that virtual currency regulatory arbitrage can be addressed via BitLicense modernization and that New York regulators share our logical provisional interpretation of cross-borders with respect to human rights. Our experience in Europe and Africa points to the necessity to work with New York regulators directly without BitLicense member interference. This approach is not to purposely irritate the esteemed Superintendent or rock the boat that is New York State and risk disrupting the system that guarantees our future. *Conditional BitLicense Approval* Modern BitLicense Logic’s opportunity is to meet a new global standard for virtual currency regulatory innovation while protecting market integrity by stringent standards applicable to all law-abiding business enterprises. In our case, a few approvals are necessary and are proposed via a hybrid model under the supervision of the Superintendent. Following this desire, we have navigated the five step process for Conditional review. 1. *Inform*: Applicants inform NYDFS of the intent to collaborate with a specific BitLicensee and provide a copy of the draft agreement between the applicant and the BitLicensee. 2. *Submit: *Applicants submit information on the expected type of business and the perceived risks, among other things. 3. *Review: *NYDFS begins its substantive review after all of the requested documentation has been submitted. 4. *Contract: *NYDFS and the applicant enter into a supervisory agreement defining the scope of the applicant’s business, shared responsibilities with its sponsor BitLicensee and NYDFS’ level of oversight. 5. *Approve:* If NYDFS approves the application, a Conditional BitLicense is issued. Every day of delay in ambiguity of Modern BitLicense Logic poses a problem for those who want to offer additional products and services at international scale while staying within the letter of the law. Currently, we believe that our Conditional application is ready to enter stage four and seek to begin negotiation of the supervisory agreement. Bloomberg as the prime example of global prestige and success fuels our desire to be best in class in providing global virtual currency financial services out of New York. Warm regards, *Gunnar Larson* Bill and Melinda Gates Scholar | Blockchain Scholar Conditional BitLicense Applicant (Global Team Lead) New York, New York 10001 -- *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 New York, New York 10001

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Wall Street’s Go-To Law Firm, Sullivan & Cromwell, Got in Bed with Crypto; Now Its Reputation Is Being Hammered
by Gunnar Larson 16 Jun '24

16 Jun '24

https://wallstreetonparade.com/2024/03/wall-streets-go-to-law-firm-sullivan… By Pam Martens and Russ Martens: March 25, 2024 ~ Ryne Miller, Former Sullivan & Cromwell Partner; Now General Counsel of FTX.US Ryne Miller, Former Sullivan & Cromwell Partner Who Became General Counsel of FTX.US Since January, the reputation of Wall Street’s go-to law firm, Sullivan & Cromwell, has been repeatedly hammered. It all stems from the law firm’s decision some years ago to involve itself in legal representations of crypto firms and/or their principals – an industry that 1,600 of the brightest scientific minds in technology have called a sham. On January 19, the Third Circuit Court of Appeals sharply rebuked the law firm’s position that it didn’t need an independent watchdog appointed by the U.S. Department of Justice to oversee the way it was handling the collapsed crypto house of frauds (known as FTX) in bankruptcy proceedings – despite it having significant conflicts of interests in the matter, such as previously providing legal representation to the mastermind of the fraud, Sam Bankman-Fried. On February 16, a federal lawsuit was filed against the law firm alleging civil conspiracy, aiding and abetting fraud, aiding and abetting breach of fiduciary duty, and violations of civil federal racketeering law in regard to its work for FTX, which had looted customer funds to the tune of billions of dollars. This month Sullivan & Cromwell is the subject of a scathing academic review related to its work for FTX by two law professors, Jonathan Lipson of Temple University-Beasley School of Law and David Skeel of the University of Pennsylvania Carey Law School. The law professors name names – including the alleged activities of key law partners at Sullivan & Cromwell related to FTX. Last year, Wall Street On Parade wrote 20 articles focusing on the glaring conflicts of Sullivan & Cromwell in the FTX matter. Common sense indicated it had rendered itself unfit for the role of lead counsel in the FTX bankruptcy proceeding. (See a relevant sample in Related Articles below.) We also provided much needed sunshine on the peculiar willingness of the presiding Judge, John Dorsey of the U.S. Bankruptcy Court for the District of Delaware, to sign off on a litany of orders that S&C requested as it enriched itself to the tune of $180 million in legal fees from the FTX bankruptcy proceedings in his court. To even casual observers, Sullivan & Cromwell’s conflicts in the FTX case were stunning. One of Sullivan & Cromwell’s law partners, Ryne Miller, had moved to FTX.US and became its General Counsel. Another former Sullivan & Cromwell lawyer, Tim Wilson, became General Counsel for FTX Ventures, the venture capital arm of FTX. Sullivan & Cromwell had not only previously represented Sam Bankman-Fried, who was convicted in November 2023 on seven counts of fraud and conspiracy, but it had also previously represented the Head of Engineering at FTX, Nishad Singh, who pled guilty to fraud charges. According to Sullivan & Cromwell’s own bankruptcy court declaration, it had been involved in more than 20 legal engagements for FTX before it filed for bankruptcy on November 11, 2022. According to the declaration, the law firm’s legal work began 15 months prior to the collapse of FTX. Sullivan & Cromwell’s conflicts with FTX and its demand to be appointed lead counsel in the bankruptcy case were so suspicious that in January of last year four sitting U.S. Senators (Elizabeth Warren (D-MA), John Hickenlooper (D-CO), Thom Tillis (R-NC) and Cynthia Lummis (R-WY)) sent a letter to Judge Dorsey. Senator Hickenlooper Tweeted a link to the letter with the comment: “Get this: FTX’s legal advisors *pre-collapse* want to be appointed to oversee investigations INTO the collapse.” The Senators’ letter drilled down as follows: “To name just one challenge: will the firm’s lawyers be able to effectively investigate their current and former partners who were central in FTX’s conduct? Additionally, given their longstanding legal work for FTX, they may well bear a measure of responsibility for the damage wrecked on the company’s victims. Put bluntly, the firm is simply not in a position to uncover the information needed to ensure confidence in any investigation or findings.” That assessment was perhaps too gentle according to the federal lawsuit filed in February against Sullivan & Cromwell by the Moskowitz Law Firm on behalf of 16 customers of the FTX crypto platform. Among the allegations in the lawsuit are the following: “…from November 2022 to mid-January 2024, S&C’s income from matters just related to FTX has surged, exceeding $180 million — or 10% of the total revenue the 900-lawyer firm publicly stated it collected in all of 2022 — with paralegals billing $595/hr. and partners billing up to $2,165/hr.” “S&C attorneys served as the primary legal services providers for the RICO enterprise, assisting in the structuring of the enterprise operations.” “When the FTX fraud was revealed in November 2022, Mr. Miller and S&C moved to consolidate power over the FTX Group without delay, quickly ousting SBF [Sam Bankman-Fried] and his lieutenants and appointing in their stead hand-picked successors to navigate FTX through the bankruptcy process. S&C’s post-collapse maneuvering seems particularly calculated, given that S&C was well positioned to see the collapse coming, via knowledge gleaned from prior engagements.” “Mr. Miller and S&C moved to divert the $250 million FTX Guaranty Fund from LedgerX, one of the few entities S&C specifically chose not to include among the over 100 FTX entities it forced into bankruptcy, in order to secure receipt of a multi-million-dollar retainer to S&C before the FTX Group filed for bankruptcy, presumably to improve the Firm’s revenues throughout the extensive FTX bankruptcy process. With S&C’s assistance, SBF [Sam Bankman-Fried] and FTX caused billions in losses to Plaintiffs through at least two separate schemes, both of which contributed to the downfall of the FTX Group.” Notwithstanding the myriad conflicts, Judge Dorsey was all-in on Sullivan & Cromwell becoming lead counsel in the FTX bankruptcy. When Sullivan & Cromwell argued against allowing the U.S. Department of Justice’s U.S. Trustee to appoint an independent examiner – a legally mandated position for bankruptcy cases exceeding $5 million — Judge Dorsey sided with the law firm. Dorsey’s decision was sharply rebuked by the Third Circuit Court of Appeals on January 19. The court wrote: “Under the Bankruptcy Court’s interpretation, the appointment of an examiner under either subsection of Section 1104(c) would be subject to a court’s discretion and a judge would have the final say as to whether an investigation was warranted. But this interpretation runs counter to the statute’s plain language and established canons of construction.” The Appeals Court also insightfully noted the following: “First, an examiner must be ‘disinterested’… This requirement of disinterest is particularly salient here, where issues of potential conflicts of interest arising from debtor’s counsel serving as pre-petition advisors to FTX have been raised repeatedly….” The U.S. Trustee has tapped Robert Cleary of law firm Patterson Belknap as its independent examiner to conduct the FTX investigation. Cleary is a former U.S. Attorney for the District of New Jersey and the Southern District of Illinois and a former Assistant U.S. Attorney in the Southern District of New York. One of the areas that Cleary will examine is if Sullivan & Cromwell’s conflicts were adequately addressed prior to its appointment as lead counsel and if it failed to disclose any material conflicts. Sullivan & Cromwell ranks among the oldest law firms in America. It was founded 145 years ago by Algernon Sydney Sullivan and William Nelson Cromwell in the financial district of lower Manhattan. During the Wall Street crisis of the 1930s, Sullivan & Cromwell built a reputation for defending Wall Street firms against shareholder lawsuits and antitrust actions. Sullivan & Cromwell also played a pivotal role in the 2008 financial crisis, the worst since the Great Depression. As Wall Street On Parade previously detailed, the firm’s Senior Chair, Rodge Cohen, paved the way for the Fed’s unprecedented $29 trillion bailout of Wall Street banks after their corrupt activities collapsed the U.S. economy in 2008. Why Sullivan & Cromwell decided to leap with both feet into the dodgy world of crypto will, hopefully, inspire another academic paper very soon. Related Articles: No One Trusts the FTX Bankruptcy Case: News Outlets Intervene; Justice Department Trustee Demands Independent Examiner; SEC Orders Disclosures A Sam Bankman-Fried Company Loaned or Invested More than $1 Billion in Clients of its Law Firm, Sullivan & Cromwell Bombshell Emails Raise Questions about What Sullivan & Cromwell Knew about Fraud at Sam Bankman-Fried’s Crypto Firms

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Enron’s Board of Directors: Contemporary Lessons on Crypto Marketplace Manipulation Computer Crimes - Crypto Computer Crimes Manual (W/183 Highlights)
by Gunnar Larson 15 Jun '24

15 Jun '24

A few years ago, I wrote an essay titled: "Enron’s Board of Directors: Contemporary Lessons on Crypto Marketplace Manipulation Computer Crimes - Crypto Computer Crimes Manual (W/183 Highlights)" https://thecapital.io/article/crypto-computer-crimes-manual-w183-highlights… Working references on disclosure controls and procedures, as well as strategic initiatives including mergers and acquisitions, joint ventures, and management restructurings (including public/private board of directors). Full, fair, and accurate disclosures from all parties in a battle for corporate influence or control are critically important to investors, particularly when they are called upon to make decisions about their investments. Contemporary crypto computer crimes likely are key considerations relevant to making informed investment decisions by sophisticated investors, underscoring protection of pension assets via keen planning. BitLicense marketplace manipulation techniques and potential cross-border computer crimes has been a major focus of xNY.io's scholar research/innovation communication and Bank.org's business plan execution strategy. The World Bank (WorldBank.org) notes that vulture funds endanger the gains made by debt relief to poorest countries. "The Bank has already delivered more than $40 billion in debt relief to 30 of these countries...thanks to this, countries like Ghana can provide micro-credit to farmers, build classrooms for their children, and fund water and sanitation projects for the poor," wrote World Bank Vice President Danny Leipziger in 2007. World Bank directors warn that strategies adopted by vulture funds divert much needed debt relief away from the poorest countries on earth and into the bank accounts of the wealthy. Bank.org is clear-eyed; microcredit lending fraud is a major issue for developing economies. Likewise, in western developed economies, market history warns that when boards of directors approve of and/or ignore the misuse of computer software programs which compute values based upon data input formulas from active cross-border manipulation structures, the results can lead to scandals like Enron. Such outcomes cost investors billions of dollars when the share prices of affected companies collapse, while also shaking public confidence in the United States securities markets. Enron’s Board of Directors: Contemporary Lessons on Crypto Marketplace Manipulation Computer Crimes In its 2000 review of best corporate boards, Chief Executive Magazine included Enron among its five best boards. Even with its complex corporate governance and network of intermediaries, Enron was still able to "attract large sums of capital to fund a questionable business model, conceal its true performance through a series of accounting and financing maneuvers, and hype its stock to unsustainable levels."On paper, Enron had a model board of directors comprised predominantly of outsiders with significant ownership stakes and a talented audit committee of various state and federal regulators. Two decades later, in 2021, it is clear that cryptocurrency and blockchain computer software systems require contemporary, ethically pure and sound cultivation to support the realization of a "generation of innovation," maximizing the full potential of blockchain software technologies. Board directors that will pioneer the next chapters of the meaningful New York legacy of global, cross-border banking will agree: Close scrutiny of corporate governance and greater responsibility placed on directors to vouch for the reports submitted to the SEC and other federal agencies have resulted in the growth of computer software solutions such as blockchain systems and processes. Cryptocurrency and Blockchain computer software products allow corporate directors and internal auditors to assemble and analyze financial and other relevant data—including unstructured data—and create reporting required by New York BitLicense regulators and various Federal counterparts. Before its demise, Enron was lauded for its sophisticated software, including financial risk management tools powered by computer software. Risk management was crucial to Enron not only because of its regulatory environment, but also because of its business plan. Enron established long-term fixed commitments which needed to be hedged to prepare for the invariable fluctuation of future energy prices. Enron's downfall was attributed to its reckless use of derivatives and special purpose formulas manipulated by computer accounting software tools. To engage in probable computer crimes, Enron hedged its risks with special purpose entities which it owned, and Enron retained the risks associated with the transactions. Enron's aggressive accounting practices were not hidden from the board of directors, as later learned by a Senate subcommittee. The board was informed of the rationale for using the Whitewing, LJM, and Raptor transactions, and after approving them received status updates on the entities' operations. Although not all of Enron's widespread improper accounting practices were revealed to the board, the practices were dependent on board decisions. Eliminating Bad Board of Director Schemes Ranging from additional corporate board responsibilities to criminal penalties, the Securities and Exchange Commission (SEC) implemented disclosure requirements to comply with the law. A recent SEC order reiterated the importance of the disclosures, noting that the requirements were adopted in order to alert the market to large and rapid accumulation of shares that might represent a possible change in corporate control so that shares can be valued accordingly. The SEC order also noted that the requirements were designed to provide an issuer’s management with timely information to appropriately protect its shareholders’ interests (including pension protections). The SEC’s recent enforcement actions relate to disclosure obligations in connection with M&A transactions and fights for corporate control. In 2015, the SEC brought forth a number of similar enforcement actions alleging that filers had failed to update their disclosures after taking steps towards certain plans and proposals. These types of enforcement actions continue to create challenging issues for practitioners, particularly when potential transactions are still in the early stages of planning and preliminary negotiation. The SEC’s historic actions serve as a reminder to investors, including vulture activists, that Schedule 13D violations can result in monetary liability and, in the case of registered funds and investment advisers, can also have other regulatory consequences. Care must be taken to avoid those communications constituting group activities with disclosure consequences. It should be noted that in some cases, coordination among the parties or sharing of information is sufficient to form prompts for disclosure purposes. Intention of Disclosing Crypto Computer Crimes Manual (W/183 Highlights) Published by the Office of Legal Education Executive office for United States Attorneys, the “Prosecuting Computer Crime Manual” has been xNY.io’s reference guide as international scholars researching Crypto Computer Crimes and how to best position corresponding Bank.org business innovation moving forward. The SEC encourages the description of any plans or proposals such as Proof of Burn (PoB) or Short Selling market activities which may relate to or would result in: The acquisition by any person of additional securities of the issuer, or the disposition of securities of the issuer; An extraordinary corporate transaction, such as a merger, reorganization or liquidation, involving the issuer or any of its subsidiaries; A sale or transfer of a material amount of assets of the issuer or any of its subsidiaries; Any change in the present board of directors or management of the issuer, including any plans or proposals to change the number or term of directors or to fill any existing vacancies on the board; Any material change in the present capitalization or dividend policy of the issuer; Any other material change in the issuer's business or corporate structure, including but not limited to, if the issuer is a registered closed-end investment company, any plans or proposals to make any changes in its investment policy for which a vote is required by section 13 of the Investment Company Act of 1940; Changes in the issuer's charter, bylaws or instruments corresponding thereto or other actions which may impede the acquisition of control of the issuer by any person; Causing a class of securities of the issuer to be delisted from a national securities exchange or to cease to be authorized to be quoted in an inter-dealer quotation system of a registered national securities association; A class of equity securities of the issuer becoming eligible for termination of registration pursuant to section 12(g)(4) of the Act; or Any action similar to any of those enumerated above. Below we share 183 highlights to the Computer Crimes Manual as per best disclosure practices to illustrate various potential scenarios when market conditions are met and a board of directors potentially exploits blockchain technological software innovation with forecastable reckless consequences. https://thecapital.io/article/crypto-computer-crimes-manual-w183-highlights…

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